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reflected on the receipts. The Court admitted these receipts
into evidence solely for the purpose of showing that some gifts
of property had been made.
Petitioner’s testimony regarding value leaves much to be
desired, as does his testimony regarding the even more
fundamental issue of deciding exactly what was donated. For
example, petitioner claims to have donated to the Salvation Army
a brand-new surround-sound radio with 12 speakers having a value
of “about maybe $400”. However, petitioner was unable to produce
a receipt for his purchase because “it was cash, actually” given
to “some guys, you know, in the parking lot” “who approached me
at Cosco” as “I was driving one day”. According to petitioner:
The speakers, you know--they were very expensive
speakers, and they gave me them at a discount price.
So I paid for the speakers, but when I go home, the
power wasn’t sufficient. It wasn’t worth what the guy
told me, so I couldn’t use it.
We accept petitioner’s testimony that he made some gifts of
property, but his proof pales in comparison to what was claimed.
As before, we exercise our discretion, but bear heavily against
petitioner, see id., and we hold that he is entitled to a
deduction for gifts of property in the amount of $250.
C. Employee Business Expenses
As an initial matter, we note that petitioner’s vehicle
expense, to the extent allowable, is a business expense
deductible under section 162(a) as a so-called above-the-line
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