William Lenihan - Page 26

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          deduction in lieu of the claimed personal deductions).  In                  
          support of that argument, respondent refers us to that portion of           
          his opening brief that, by the supplement to brief, he asked us             
          to disregard.  We have done so and assume that, at least in this            
          case, respondent has disregarded his argument that petitioner has           
          failed to file a return on which he itemized his deductions.  We            
          treat petitioner as having on the Nov. 10 return elected to                 
          itemize his deductions.                                                     
               The parties have jointly stipulated four exhibits containing           
          photocopies of bank checks and other items that petitioner                  
          produced with respect to his claimed Schedule A deductions.                 
          Respondent does not stipulate that the documents making up the              
          exhibits substantiate the claimed expenses.  Those documents,               
          like the ones previously discussed, are, in many respects                   
          inadequate to substantiate the expenses claimed.  For instance,             
          to substantiate a portion of the amount that petitioner claims he           
          paid as property tax on his Connecticut residence, petitioner               
          offers a check drawn on an account of II Mortgages.  In support             
          of his charitable deductions, he offers a check apparently drawn            
          on an account of Equity Investments.  Another check, drawn to the           
          order of “Senior Center”, is accompanied by no further                      
          information.  A letter apparently justifying a charitable                   
          deduction of $30 states that the $30 is the cost of lunch                   
          “[including] an open bar”.  In support of his claim of a casualty           






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