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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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