Betty Kendrix - Page 17

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          unspecified origin which purports to list “suggested price                  
          ranges” developed “with the help of Salvation Army and Goodwill”            
          for those types of items.  Petitioner argues that her valuations            
          are within the suggested ranges.  As stated supra, attachments to           
          briefs are not evidence and may not be considered.                          
               Respondent argues that petitioner is not entitled to any               
          deduction for her alleged noncash contributions because her                 
          contribution claims lack credibility and because they do not                
          satisfy the substantiation requirements of the Code and                     
          regulations.                                                                
               Petitioner testified that all of the donated items either              
          were purchased from the son of a deceased girlfriend who needed             
          the money ($3,000) to buy drugs, or were purchased (or picked up)           
          “off the street” and refurbished by her.  Petitioner also cites             
          distributions from her thrift plan as a source of funds used to             
          purchase the donated items, although she also testified that she            
          needed and used those funds for living expenses.                            
               Respondent finds petitioner’s testimony to be “implausible             
          and uncorroborated,” and he concludes, on the basis of the                  
          evidence, that “petitioner lacked the property that she claims to           
          have contributed.”  Respondent lists several reasons for his                
          skepticism.  He notes the discrepancy between petitioner’s 1998             
          return, in which she reported cash charitable contributions of              
          $15,000, and her representations in her bankruptcy petition,                






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