- 23 -
unless they actually contributed the videos to the charity and
substantiated the contribution with a receipt from the charity
for the donation.
We next turn to petitioners’ contributions of property.
Petitioners provided a receipt from the CAP Agency, and Mrs.
Wasik testified she added the amount, $1,284, to the receipt.
Petitioners also introduced a detailed three-page handwritten
list of the items donated and the estimated values, totaling
about $3,800, well over the $1,284 written on the receipt.
Petitioners stated on the return, however, that they donated
property worth $1,073 to Goodwill Industries. Mrs. Wasik stated
that when preparing the detailed list of items, she simply
estimated their values according to what each item was and how
old it was.
We are troubled by the significant inconsistencies and
contradictions in the evidence and testimony on this issue.
Petitioners introduced a receipt from an organization different
from the organization they claimed on their return. In addition,
petitioners’ tax return reflects a different amount from
petitioners’ receipt, which reflects a still different amount
from petitioners’ handwritten notes. Mrs. Wasik did not explain
these discrepancies at trial to the Court’s satisfaction.
We do not find this inconsistent, contradictory testimony to
be credible, and we decline to accept it. We find that
Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: November 10, 2007