- 10 - 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-linePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 NextLast modified: March 27, 2008