James Warren - Page 3

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               Respondent determined deficiencies in petitioner’s Federal             
          income taxes of $813 in 2002 and $1,300 in 2003.  After                     
          concessions by petitioner,2 the issues for decision are:  (1)               
          Whether petitioner is entitled to deductions on Schedule A,                 
          Itemized Deductions, for cash charitable contributions of $4,500            
          for 2002 and $1,000 for 2003 and (2) whether petitioner is                  
          entitled to deductions on Schedule A for noncash charitable                 
          contributions of $500 each for 2002 and 2003.                               
               Some facts have been stipulated and are so found.  The                 
          stipulation of facts and the attached exhibits are incorporated             
          by this reference.  When the petition was filed, petitioner                 
          resided in Downingtown, Pennsylvania.                                       
               Two computer-generated lists of contributions allegedly made           
          to The Church of Faith (the church) in Raleigh, North Carolina,             
          showing contributions of $85 for each week from January 6 to                
          November 10, 2002, $90 for each of the next 6 weeks, $135 for the           
          last week of 2002 (totaling $4,500 in 2002), and $20 per week               
          from January 5 to December 14, 2003 (totaling $1,000 in 2003),              
          were presented at trial.  The lists indicate that each                      
          contribution was made in cash.  The lists were prepared by                  
          Chester Muhammad or his daughter and were provided to petitioner            
          by Mr. Muhammad’s daughter.  Mr. Muhammad was petitioner’s                  


               2 Petitioner does not contest a disallowed deduction for a             
          casualty and theft loss of $4,467 for 2003.                                 





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