Bobby Lorn and Libby C. Claborn - Page 3




                                        - 2 -                                         
          is not reviewable by any other court, and this opinion shall not            
          be treated as precedent for any other case.                                 
               Respondent determined a deficiency in petitioner’s Federal             
          income tax for the 2003 taxable year in the amount of $3,592.               
          The issues now before the Court are:  (1) Whether petitioners are           
          entitled to an itemized deduction of $2,096 for charitable                  
          contributions of cash to First Presbyterian Church in                       
          Chattanooga, Tennessee (church);2 (2) whether petitioners are               
          entitled to an itemized deduction in excess of the $25 respondent           
          allowed for their charitable contribution of property to the                
          Salvation Army; and (3) whether petitioners are entitled to a               
          miscellaneous itemized deduction of $21,729 for unreimbursed                
          employee expenses.                                                          



               2  Respondent concedes that petitioners are allowed a $500             
          deduction for 20 separate $25 contributions made to their church            
          in 2003 by check through the use of tithing envelopes.  On their            
          2003 Federal income tax return, petitioners claimed only a $2,000           
          deduction for contributions to their church in cash rather than             
          by check.  At trial, petitioners claimed such cash contributions            
          in the amount of $2,096, as set forth on a self-prepared itemized           
          schedule they prepared for trial.  That schedule showed cash                
          contributions by week to “Lee Anderson’s Class”; “Children’s                
          Class”; and “Church Offering”.  The totals for 2003 were $84, $85           
          (but petitioners claimed $87 as the result of an addition error),           
          and $1,925, respectively.  The weekly donations to each of the              
          two “classes” were $2 with one exception, a $1 donation to the              
          “Children’s Class” for the week of June 22.  Respondent also                
          concedes that petitioners are entitled to a $250 deduction for              
          contributions made to the Lookout Mountain Education Fund in                
          2003.  That deduction was not allowed in the statutory notice of            
          deficiency that was issued by respondent in this case.                      






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