Paul Christopher and Kandl Lei Robinson - Page 3




                                        - 2 -                                         
          Revenue Code in effect for the years in issue, and all Rule                 
          references are to the Tax Court Rules of Practice and Procedure.            
               Respondent determined deficiencies in petitioners’ 2002 and            
          2003 Federal income taxes of $2,928 and $2,139, respectively.               
          After concessions,1 the issue for decision is whether petitioners           
          are entitled to charitable contribution deductions.                         
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and attached exhibits, as well as an               
          additional exhibit introduced at trial, are incorporated herein             
          by this reference.  At the time the petition was filed,                     
          petitioners resided in Clarksville, Maryland.                               
               Petitioners timely filed joint 2002 and 2003 Federal income            
          tax returns.  On their 2002 return, petitioners reported adjusted           
          gross income of $79,864 and claimed a $20,900 deduction for cash            
          contributions.  On their 2003 return, petitioners reported                  
          adjusted gross income of $72,937 and claimed a $20,511 deduction            
          for cash contributions.2  Respondent issued petitioners a notice            
          of deficiency in September 2005 disallowing $19,400 of the                  
          deductions claimed for 2002 and $19,011 of the deductions claimed           



               1 For 2002, respondent concedes that petitioners are                   
          entitled to expense deductions claimed on Schedule E,                       
          Supplemental Income and Loss.                                               
               2 Petitioners also claimed $2,650 in noncash contributions             
          on their 2003 return.  Respondent allowed this noncash                      
          contribution deduction, and therefore it is not at issue.                   





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