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Petitioners also attached a form entitled “Itemized Gifts
and Donations to the Salvation Army” to their return. On this
form, petitioners listed the value of the items donated to the
Salvation Army as follows:
Items Value
25 Jackets $1900
256 Clothes 5601
110 Pair [sic] of shoes 2485
45 Fashion bags 1588
10 Irons and boards 200
30 Backpacks 255
Furniture 5560
20 Household appliances 300
Total $17,889
With respect to the aforementioned items, petitioners did
not attach a Form 8283, Noncash Charitable Contributions, or any
other statement of appraisal to their return.
Respondent issued petitioners a notice of deficiency in
January 2006. Respondent disallowed in full the claimed
deductions and determined a $4,283 deficiency in petitioners’
2003 income tax. Petitioners filed a petition for review of
respondent’s determination. Petitioners resided in Shorewood,
Wisconsin, when their petition was filed.
Discussion
Deductions are a matter of legislative grace and are allowed
only as specifically provided by statute. INDOPCO, Inc. v.
Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v.
Helvering, 292 U.S. 435, 440 (1934). Generally, the taxpayer
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