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at its drop boxes, where there are no receipts. Petitioners did
not offer any evidence as to what, where, or when the non-cash
items were donated to the Salvation Army.
We are not convinced on the basis of our review of the
entire record that petitioners are entitled to claim an $18,500
deduction for gifts to charity.
Finally, with respect to the other miscellaneous $12,000
deduction claimed for “home winterization”, Mr. Ingram admitted
that he mistakenly duplicated this amount from the amount claimed
for repairs on Schedule E for Property B.
Accordingly, and based on the foregoing, respondent’s
determination is sustained with respect to the $24,788 of
Schedule A deductions disallowed in the notice of deficiency. We
also hold that respondent has satisfied the burden of proof with
respect to the $48,565 of Schedule A deductions disallowed in the
answer.
Rental Income
Mrs. Burkley admitted receiving rent from Property A and B
in 2002 as follows: (1) Property A--$2,000, (2) Property B,
second floor--$2,000, and (3) Property B, third floor--$1,500.
Respondent pleaded in the answer that petitioners did not report
the rents collected on Property A and B as income on their
return.
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