Sparrow v. Commissioner

U.S. Tax Court

Sparrow v. Commissioner

1988 T.C. Memo. 99, 55 T.C.M. 335, 1988 Tax Ct. Memo LEXIS 129

CourtUnited States Tax Court

DecidedMarch 7, 1988

DocketDocket No. 17056-79.

StatusUnpublished

This text of 1988 T.C. Memo. 99 (Sparrow v. Commissioner) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Sparrow v. Commissioner, 1988 T.C. Memo. 99, 55 T.C.M. 335, 1988 Tax Ct. Memo LEXIS 129 (tax 1988).

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Opinion

CLEVELAND BUCHANAN SPARROW, SR., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Sparrow v. Commissioner

Docket No. 17056-79.

United States Tax Court

T.C. Memo 1988-99; 1988 Tax Ct. Memo LEXIS 129; 55 T.C.M. (CCH) 335; T.C.M. (RIA) 88099;

March 7, 1988.

Cleveland Buchanan Sparrow, Sr., pro se.

Robert E. Langley, for the respondent.

CANTREL

MEMORANDUM FINDINGS OF FACT AND OPINION

CANTREL, Special Trial Judge:¹ In his joint notice of deficiency issued to petitioner and Joyce S. Sparrow,

2 respondent determined deficiencies in Federal income tax and additions to the tax for the taxable years 1974 through 1976 as follows:

		Additions to Tax, I.R.C. 1954
Years	Income Tax	Section 6653(a)
1974	$ 481.23	$ 57.95
1975	460.89	49.55
1976	503.00	35.95

*132 The following adjustments to income were determined by respondent in his notice:

	1974	1975	1976
Contributions	$ 610.00	756.00	$ 409.00
Medical	637.00	525.00	612.00
Employee Business
Expenses	1,500.00	1,170.00	1,500.00
Education	(180.00)	-0-	-0-
Union Dues	(21.00)	(26.00)	(26.00)
Remaining Itemized
Deductions	1,988.00	-0-	-0-
Standard
Deduction	(2,000.00)	-0-	-0-
	$ 2,534.00	$ 2,425.00	$ 2,495.00

The issues for decision are:

1. Whether petitioner is entitled to charitable deductions for 1974, 1975 and 1976 in amounts greater than allowed by respondent.

2. Whether petitioner is entitled to medical deductions for 1974, 1975 and 1976 in amounts greater than allowed by respondent.

3. Whether petitioner is entitled to employee business expenses for 1974, 1975 and 1976 in amounts greater than allowed by respondent.

4. Whether petitioner is entitled to education expenses in 1974, 1975 and 1976 in amounts greater than allowed by respondent.

5. Whether petitioner's underpayments of income tax for 1974, 1975 and 1976 are due to negligence or intentional disregard*133 of rules and regulations within the meaning of section 6653(a). ³

FINDINGS OF FACT

Petitioner resided at 843-52nd Street, N.E., Washington, D.C. (hereinafter sometimes called the "52nd Street residence") on the date he filed his petition herein. He and his spouse, Ms. Sparrow, filed joint 1974, 1975 and 1976 Federal income tax returns (hereinafter "return" or "returns") with the Director, Internal Revenue Service Center, Philadelphia, Pennsylvania. Those returns were prepared by Evan Brown an accountant, from information supplied by petitioner.

During 1974, 1975 and 1976 petitioner was employed full-time by the Department of the Navy (hereinafter "Navy Dept.") as a computer specialist. During these years he received gross wages in*134 the respective amounts of $ 13,338.40, $ 14,259.20 and $ 14,777.02, all of which was reported on the returns filed for those years. ⁴ No other income was reported on those returns. Ms. Sparrow was a housewife during these years. The Forms W-2⁵ show petitioner's gross wages and deductions therefrom to be:

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CLEVELAND BUCHANAN SPARROW, SR., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Sparrow v. Commissioner

Docket No. 17056-79.

United States Tax Court

T.C. Memo 1988-99; 1988 Tax Ct. Memo LEXIS 129; 55 T.C.M. (CCH) 335; T.C.M. (RIA) 88099;

March 7, 1988.

Cleveland Buchanan Sparrow, Sr., pro se.

Robert E. Langley, for the respondent.

CANTREL

MEMORANDUM FINDINGS OF FACT AND OPINION

CANTREL, Special Trial Judge:¹ In his joint notice of deficiency issued to petitioner and Joyce S. Sparrow,

		Additions to Tax, I.R.C. 1954
Years	Income Tax	Section 6653(a)
1974	$ 481.23	$ 57.95
1975	460.89	49.55
1976	503.00	35.95

*132 The following adjustments to income were determined by respondent in his notice:

	1974	1975	1976
Contributions	$ 610.00	756.00	$ 409.00
Medical	637.00	525.00	612.00
Employee Business
Expenses	1,500.00	1,170.00	1,500.00
Education	(180.00)	-0-	-0-
Union Dues	(21.00)	(26.00)	(26.00)
Remaining Itemized
Deductions	1,988.00	-0-	-0-
Standard
Deduction	(2,000.00)	-0-	-0-
	$ 2,534.00	$ 2,425.00	$ 2,495.00

The issues for decision are:

1. Whether petitioner is entitled to charitable deductions for 1974, 1975 and 1976 in amounts greater than allowed by respondent.

2. Whether petitioner is entitled to medical deductions for 1974, 1975 and 1976 in amounts greater than allowed by respondent.

3. Whether petitioner is entitled to employee business expenses for 1974, 1975 and 1976 in amounts greater than allowed by respondent.

4. Whether petitioner is entitled to education expenses in 1974, 1975 and 1976 in amounts greater than allowed by respondent.

5. Whether petitioner's underpayments of income tax for 1974, 1975 and 1976 are due to negligence or intentional disregard*133 of rules and regulations within the meaning of section 6653(a). ³

FINDINGS OF FACT

Petitioner resided at 843-52nd Street, N.E., Washington, D.C. (hereinafter sometimes called the "52nd Street residence") on the date he filed his petition herein. He and his spouse, Ms. Sparrow, filed joint 1974, 1975 and 1976 Federal income tax returns (hereinafter "return" or "returns") with the Director, Internal Revenue Service Center, Philadelphia, Pennsylvania. Those returns were prepared by Evan Brown an accountant, from information supplied by petitioner.

During 1974, 1975 and 1976 petitioner was employed full-time by the Department of the Navy (hereinafter "Navy Dept.") as a computer specialist. During these years he received gross wages in*134 the respective amounts of $ 13,338.40, $ 14,259.20 and $ 14,777.02, all of which was reported on the returns filed for those years. ⁴ No other income was reported on those returns. Ms. Sparrow was a housewife during these years. The Forms W-2⁵ show petitioner's gross wages and deductions therefrom to be:

	1974	1975	1976
Gross Wages	$ 13,338.40	$ 14,259.20	$ 14,777.02
Less: Federal Income
Tax Withheld	1,185.32	1,178.85	1,180.89
Local Income
Tax Withheld	295.88	353.10	398.08
Health Insurance
Withheld	396.61
Balance	$ 11,460.59	$ 12,727.25	$ 13,198.05

During the years at bar, petitioner and Ms. Sparrow owned the 52nd Street residence*135 as tenants by the entireties, i.e., they held title to the whole with right of survivorship so that, upon the death of either, the other takes whole to the exclusion of the heirs of the deceased. During these years they lived in said residence together with their four children, Cleveland Jr., Solomon, Noah and James.

During 1974-1975 and part of 1976, the 52nd Street residence contained six rooms consisting of three bedrooms, one full bath, living room and a kitchen. A desk was maintained in one of the bedrooms. At some unspecified time in 1976, a six room addition to said residence was completed. The residence then consisted primarily of four bedrooms, one full bath, kitchen, storage area, dining room, living room, a half-room office on the second floor and a basement. The telephone during this entire period was listed in petitioner's name.

During the years at dispute petitioner and Ms. Sparrow maintained joint checking account no. XX-XXXX1557 at the Riggs National Bank, Washington, D.C. (hereinafter sometimes referred to as "RNB" or the "personal account"). More than 415 checks drawn on that account, virtually all of which were prepared and signed by Ms. Sparrow, were submitted*136 at trial. ⁶ However, no bank statements or deposit slips were submitted and many checks are missing. ⁷

At the time of trial petitioner had been a Baptist minister for some 25 years and during that time had worked in various churches and organizations. Throughout 1974 and up to January 25, 1975 he was the President of United American Appeal ("United American"), which was not a church and for which he worked as a minister. United American's purpose was to carry on community religious activities such as the Mayor's Youth Program, parades, revivals, prayer breakfasts and luncheons. The headquarters of United American was the 52nd Street residence. During this period United American maintained checking account no. X-XX158-2 at the Bank of Virginia, Arlington, Virginia (hereinafter sometimes referred to as the "Bank of Va." or, for the purpose of simplicity, the "separate account"). Petitioner was the sole signatory on this account. He had total control over the management and financial*137 affairs of United American, including the deposits made to and the checks drawn on this account. Checks were drawn on this account for such things as charitable contributions, a home mortgage payment, dry cleaning, clothes, shoes, doctors, prescriptions and TV repairs. While deposit slips and checks pertaining to this account were submitted by petitioner, no bank statements were submitted and many checks are missing. ⁸

United American was not an entity as defined in section 170(c), contributions to which would be deductible under section 170(a). In addition, it never applied for and was never granted tax exempt status under section 501(a). United American was nothing more than the alter ego of petitioner. ⁹

On January 25, 1975, Sparroworld Baptist Corporation (hereinafter sometimes called "Sparroworld"), United American's successor, was incorporated. On or about August 18, 1977, Sparroworld*138 through petitioner, its President, submitted a Form 1023, Application for Recognition of Exemption Under Section 501(c)(3) of the Internal Revenue Code, to the Internal Revenue Service. Therein it advises that its sources of financial support include churches and religious organizations in the Washington, D.C. metropolitan area and that it has been and continue to be involved in community activities, including the keeping of prayer in the public school systems. It further reports that it has promoted its activities through a prayer breakfast and through messages delivered by "Reverend Cleveland B. Sparrow." Additionally, it states that it has no members but that it does have a board of directors which consists of petitioner, Ms. Sparrow and Rev. Walter A. Grey (who was deceased at the time of trial). By letter dated March 2, 1978, the Internal Revenue Service notified Sparroworld in part --

Based on information supplied, and assuming your operations will be as stated in your application for recognition of exemption, we have determined you are exempt from Federal income tax under section 501(c)(3) of the Internal Revenue Code.

*139 * * *

Donors may deduct contributions to you as provided in section 170 of the Code. * * *

Sparroworld's headquarters in 1975 and 1976 was the 52nd Street residence. The corporation continued to maintain the separate account at the Bank of Va. Petitioner remained the sole signatory on this account. While deposit slips and checks relating to the account were submitted by petitioner, no bank statements were submitted and many checks are missing. ¹⁰

Sparroworld, which likewise is not a church, was a viable, separate taxable entity, apart from petitioner. ¹¹

As a minister and president of United American and Sparroworld, petitioner gave sermons, lectures and speeches for which he was remunerated. This income was not reported by either United American or Sparroworld since, according to petitioner, neither*140 had gross income in excess of $ 10,000.00 a year. However, all of this income, amounts unknown, was deposited in the separate account. In addition, both United American and Sparroworld received contributions, amounts also unknown, from churches, individuals and other religious organizations, all of which were similarly deposited in the separate account.

In 1970, petitioner received a bachelor's degree from Federal City College, Washington, D.C. and in 1973 he received a master's degree from the same institution. During 1974-1976 he took a number of courses at Virginia Polytechnic Institute and State University ("VPI"), courses that would lead to a doctor's degree in adult education. In the Winter 1976 Term (i.e., during January, February and March) he took and successfully completed courses in the Fundamentals of Accounting and Financial Planning. As a result of taking these courses, which he completed prior to the time he filed the returns at dispute, he acquired more than a passing knowledge about balance sheets and profit and loss statements. In addition, he was instructed that individuals and corporations were separate taxable entities.

Contributions

It was petitioner's*141 habit during 1974-1976 to take his pay check from the Navy Dept. to the Bank of Va. where he would either deposit his whole check in the separate account or a large portion thereof receiving back a small portion in cash.

Petitioner claimed charitable contributions as itemized deductions on the 1974, 1975 and 1976 returns. ¹² The amounts of the deductions claims, the amounts allowed and disallowed by respondent are:

	1974	1975	1976
Claimed ¹³	$ 1,000.00	$ 1,500.00	$ 1,500.00
Allowed	390.00	744.00	1,091.00
Disallowed	$ 610.00	$ 756.00	$ 409.00

Checks (in the aggregate) reflecting charitable contributions for which petitioner would be entitled to a deduction in 1974, 1975 and 1976 as follows:

Separate Account			Personal Account
1974	1975	1976	1974	1975	1976
$ 140.49	¹⁴ $ 7.00	¹⁵ 0	¹⁶ $ 19.00	¹⁷ $ 834.00	¹⁸ $ 19.00

*142

*143 In sum, based on the record, petitioner is entitled to the following deductions for contributions: $ 390.00 for 1974; $ 841.00 for 1975 and; $ 1,091.00 for 1976.

Medical Expenses

Petitioner claimed medical expense deductions on the 1974, 1975 and 1976 returns. For these years, medical expense deductions are calculated by reference to a taxpayer's adjusted gross income: medical expenses are deductible to the extent they exceed 3 percent of adjusted gross income. Medicine and drug expenses are deductible as medical expenses to the extent that they exceed 1 percent of adjusted gross income. ¹⁹ The deductions claimed by petitioner, the amounts allowed and disallowed by respondent are as follows:

	1974	1975	1976
Claimed	$ 907.12	$ 1,021.85	$ 1,091.32
Allowed	270.12	496.85	479.32
Disallowed	$ 637.00	$ 525.00	$ 612.00

On the 1974, 1975 and 1976 returns petitioner claimed expenses in the following amounts for insurance premiums for medical care, medicine and drugs, doctor bills and transportation:

	1974	1975	1976
Insurance Premiums	$ 396.61	$ 396.61	$ 513.13
Medicine and Drugs	304.00	345.60	298.27
Doctor's Bills	600.00	700.00	721.00
Transportation ²⁰	80.00	90.00	90.00
	$ 1,380.61	$ 1,532.21	$ 1,622.40

*144

Medical expenses were paid in 1974, 1975 and 1976 to doctors and for prescriptions by petitioner, United American and Sparroworld. ²¹ Checks reflecting these payments (in the aggregate) are as follows:

Separate Account
1974		1975		1976
DR.	RX	DR.	RX	DR.	RX
$ 70.00	$ 13.20	$ 15.00	0	0	0

Personal Account
1974		1975		1976
DR.	RX	DR.	RX	DR.	RX
$ 194.00	$ 94.15	$ 237.00	$ 131.49	$ 409.00	$ 272.65

Based on the evidence of record petitioner is entitled to a medical expense deduction for 1975 in the amount of $ 269.73, which is $ 227.12 less than the amount allowed by respondent. ²² However, petitioner is entitled to medical expense deductions in 1974 and 1976 in the respective amounts of $ 305.46 (which is $ 35.34 more than the amount allowed by respondent) and $ 663.70 (which is $ 184.38 more than the amount allowed by respondent). ²³

*145

Employee Business Expenses

Petitioner claimed automobile expenses on the 1974, 1975 and 1976 returns. These expenses were reported as having been incurred on behalf of United American and Sparroworld. ²⁴ The amounts claimed, the amounts allowed and disallowed by respondent are:

	1974	1975	1976
Claimed ²⁵	$ 1,500.00	$ 1,500.00	$ 1,500.00
Allowed	0	330.00	0
Disallowed	$ 1,500.00	$ 1,170.00	$ 1,500.00

In each year in issue petitioner reported that his personal automobile was driven 22,000 miles, of which 10,000 miles in each year was for business purposes. He maintained no records or diary reflecting mileage for business purposes. Checks reflecting payments (in the aggregate) for gasoline and oil are as follows:

Separate Account			Personal Account
1974	1975	1976	1974	1975	1976
$ 304.27	²⁶ $ 833,97	²⁷ $ 630.72	$ 193.71	$ 533.18	$ 760.02

*146

Education Expenses

Petitioner claimed no expense for education on the 1974, 1975 and 1976 returns. During the audit of petitioner's returns he claimed entitlement to such expenses. Respondent allowed an educational expense for 1974 in the amount of $ 180.00 for courses taken which respondent determined maintained and improved petitioner's skills as a computer specialist. Respondent allowed no expense for courses taken in 1975 or 1976. Checks reflecting payments for education (in the aggregate) are as follows:

Separate Account			Personal Account
1974	1975	1976	1974	1975	1976
$ 68.95	$ 368.30	²⁸ $ 376.75	²⁹ -0-	³⁰ $ 126.00	-0-

*147 Section 6653(a) Additions to Tax

Petitioner is an educated man. He knew, prior to the time he filed the returns involved herein, that individuals and corporations were separate taxable entities. For reasons of his own he persisted, throughout the years involved herein, to commingle his only reported income, i.e., his wages from the Navy Dept., with income and contributions received by or on behalf of United American and Sparroworld. He kept no books and records which would accurately reflect his personal income and expenses or the income, contributions and expenses of either United American or Sparroworld.

Petitioner knew that his returns for each of the years at bar were to be filed on or before April 15 of the succeeding taxable year. Notwithstanding, the 1974 return, which is dated April 14, 1975 and which should have been filed on April 15, 1975, was filed on May 3, 1976. The 1975 return, which is dated April 12, 1976 and which should have been filed on April 15, 1976, was filed on May 4, 1976. The 1976 return, which is dated April 14, 1977 and which should have been filed on April 15, 1977, was filed on June 23, 1977. ³¹

*148 OPINION

At the outset, we think it not only appropriate but necessary to make a few observations. On the date this case was first called for trial the parties represented to the Court that additional time was needed to discuss the possibility of settlement or to ready the case for trial. A short continuance was granted. Thereafter, pursuant to the parties' requests, the case was twice more continued. When the case was finally tried, some 4 months after it had first been called for trial, petitioner was no better prepared than on the date the case was originally called.

We have before us a 313 page transcript wherein we find petitioner's rambling testimony to be at times confusing, conflicting and downright baffling. During the course of the trial petitioner proceeded to dump on the Court over 860 checks together with a number of exhibits. To make matters worse, it is impossible to determine how respondent arrived at his disallowances. In such posture, we have devoted an inordinate amount of time to this record. We have done the best we can in order to come up with what we think is the correct result. ³²

*149

Rule 142(a) states in pertinent part that "the burden of proof shall be upon the petitioner, * * *." Petitioner was repeatedly advised by the Court, both before and during the trial, that the burden of proof was upon him with respect to every issue placed at dispute.

It is well settled that petitioner has the burden of proving respondent's determinations are incorrect. Welch v. Helvering,290 U.S. 111 (1933). Moreover, with respect to deductions, taxpayers are required to maintain and present for examination books and records to establish their rights to the deductions claimed. New Colonial Ice Co. v. Helvering,292 U.S. 435 (1934); section 6001.

Section 170(a) allows as a deduction any charitable contribution, as defined in subsection (c), paid in a taxable year, subject to limitations set forth in section 170(b).

We have found that petitioner is entitled to a deduction for charitable contributions for 1975 in the amount of $ 841.00, *150 which is more than the amount allowed by respondent. Petitioner has produced no probative evidence to show that he is entitled to a deduction in a greater amount. For 1974 and 1976 he has produced no probative evidence showing that he is entitled to deductions in amounts greater than allowed by respondent. Accordingly, we sustain respondent's determination for 1974 and 1976. Welch v. Helvering, supra;Rule 142(a).³³

Section 213 provided a deduction for medical expenses not compensated for by insurance or otherwise in an amount by which such expenses paid during the taxable year exceed 3 percent of adjusted gross income.

We have found that petitioner is entitled to medical expense deductions in 1974 and 1976 in the amounts of*151 $ 305.46 and $ 663.70, which said amounts are greater than the amounts allowed by respondent. Petitioner has produced no probative evidence to show that he is entitled to deductions of higher amounts. For 1975 he has produced noo probative evidence showing that he is entitled to a deduction in an amount greater than allowed by respondent. We, therefore, sustain respondent's determination for 1975. Welch v. Helvering, supra;Rule 142(a).

Under section 162(a) an employee or self-employed individual may deduct the cost of operating an automobile to the extent it is used in a trade or business. Furthermore, three conditions must be satisfied before a deduction will be allowed for a claimed business expense under section 162(a). ³⁴ It must be (1) incurred in carrying on a "trade or business," (2) "ordinary and necessary," and (3) "paid or incurred during the taxable year." A business purpose is implicitly required by section 162(a). Whether an expenditure qualifies as an ordinary and necessary expense incurred in a trade or business*152 is an issue of fact. Commissioner v. Heininger,320 U.S. 467, 475 (1943).

For the years 1974-1976 a taxpayer may use a simplified method to calculate the deduction. It can be computed using a standard mileage rate $ .15 per mile for the first 15,000 miles of business use each year. A deduction under this method is in lieu of all operating and fixed costs allocable to business purposes, including fuel and depreciation. This method was used by petitioner. However, petitioner maintained no diary or records that would reflect mileage for business purposes. It is not possible to make any allocation on this record. Petitioner has wholly failed to show that he is entitled to any expense for use of his automobile for business purposes. Respondent's determinations are sustained. Welch v. Helvering, supra;Rule 142(a).

Respondent allowed petitioner an education expense in 1974. Petitioner has wholly failed to*153 produce any probative evidence to show that he is entitled to an educational expense for any of the years at bar in excess of the amounts determined by respondent and, therefore, respondent's determinations are sustained. Welch v. Helvering, supra;Rule 142(a).

Section 6653(a) Additions to Tax

Respondent determined that petitioner is liable for the additions to the tax under section 6653(a) for the taxable years 1974 through 1976.³⁵ Negligence under section 6653(a) is lack of due care, or failure to do what a reasonble and ordinarily prudent person would do under the circumstances. Neely v. Commissioner,85 T.C. 934, 947 (1985). Respondent's determinations that petitioner's underpayments of tax were due to negligence or intentional disregard of rules and regulations is "presumptively correct and must stand unless the taxpayer can establish that he was not negligent." Hall v. Commissioner,729 F.2d 632, 635 (9th Cir. 1984). Petitioner therefore bears the burden of proving that he is not liable for the additions to the tax. Rule 142(a); Bixby v. Commissioner,58 T.C. 757, 791 (1972); Enoch v. Commissioner,57 T.C. 781, 802 (1972).*154

Petitioner is an educated and intelligent man. Indeed, in addition to being awarded an undergraduate degree and a master's degree, he has taken and successfully completed some 10 courses leading to a doctorate in adult education. He was, by his own admission, aware of the fact that individuals and corporations were separate taxable entities. Yet, for reasons of his own, he deliberately commingled his only reported income, i.e., his salary from the Navy Dept., with the income and contributions received by or on behalf of United American and Sparroworld. See Boyer v. Commissioner,69 T.C. 521, 538-539 (1977). He kept no books and records which would accurately reflect his*155 income and expenses or the income, contributions and expenses of either United American or Sparroworld. Many of the items he seeks a deduction for are personal items for himself or members of his family which were paid by Sparroworld, a corporation. Those items, if deductible, would be deductible by the corporation, not petitioner. Finally, while petitioner was admittedly aware of the fact that the returns at dispute were to be filed by April 15, of the following year, all the returns were filed late. Petitioner's conduct here shows without question a lack of due care and a failure to do what a reasonable and ordinarily prudent person would do under the circumstances. Petitioner is liable for the additions to the tax under section 6653(a). See Patel v. Commissioner,T.C. Memo. 1988-33, and Walter v. Commissioner,T.C. Memo. 1980-31. Respondent's determinations, therefore, are sustained. ³⁶

Finally, we address and answer other contentions raised by petitioner during trial --

(a) That he is entitled to office-in-home*156 expenses for each year at bar. Suffice it to say that there is no probative evidence in the record showing that he is entitled to such expenses.

(b) That, as president of Sparroworld, he attended the World Baptist Convention in Stockholm, Sweden, in 1975 and is entitled, as a business expense, to all expenses incurred and paid for in connection with that trip. The record is otherwise. Indeed, the record strongly indicates that all of those expenses were paid for by Sparroworld, a corporation and not by petitioner.

(c) That he is entitled to expenses, either as a charitable contribution or as a business expense for a prayer breakfast in 1976. The record shows that approximately one-half of those expenses were paid by the individuals who attended the breakfast and the balance was paid by Sparroworld.

(d) That he was unable to fully substantiate his claimed deductions and expenses because many of the checks that were submitted to respondent's audit agent were not returned to him or his representative. Respondent vehemently resists this contention. The record simply does not support petitioner's self-serving statement. Further, petitioner did not call or subpoena his representative*157 as a witness. Since he did not do so, we assume that the testimony of his representative would not have been favorable. See Wichita Terminal Elevator Co. v. Commissioner,6 T.C. 1158, 1165 (1946), affd. 162 F.2d 513 (10th Cir. 1947).

In accord with the foregoing,

Decision will be entered under Rule 155.

Appendix A

1974, 1975 and 1976 Deposit Tickets Bank of Va. Checking Account No. 7-07158-2 United American/Sparroworld Rev. Cleveland B. Sparrow, Sr., President

1974
Date	Amount
1-4-74	$ 430.00
1-17-74	375.00
1-30-74	380.00
2-15-74	338.38
3-4-74	350.00
3-28-74	370.00
4-26-74	370.00
5-8-74	21.12
5-8-74	370.00
5-22-74	370.00
5-22-74	21.12
6-3-74	170.00
6-4-74	391.12
6-18-74	350.00
7-3-74	325.00
7-17-74	391.12
7-31-74	370.00
8-15-74	380.00
8-29-74	370.00
9-11-74	400.12
9-26-74	391.12
10-11-74	250.00
10-24-74	370.00
12-17-74	421.55
12-21-74	400.00
	$ 8,375.65

1975
Date	Amount
1-2-75	$ 200.00
1-21-75	100.00
1-30-75	140.00
2-24-75	220.00
3-10-75	200.00
3-25-75	422.61
4-16-75	150.00
4-25-75	75.00
5-6-75	400.00
5-19-75	100.00
5-21-75	400.00
5-27-75	60.00
6-3-75	400.00
6-17-75	400.00
6-23-75	35.00
6-30-75	250.00
7-3-75	1,071.08
7-15-75	100.00
7-29-75	400.00
8-12-75	432.53
8-26-75	400.00
9-9-75	432.53
9-23-75	400.00
10-6-75	20.00
10-7-75	382.53
10-10-75	6,800.00
10-29-75	1,900.00
11-12-75	400.00
11-26-75	350.66
12-4-75	375.00
12-18-75	350.00
12-31-75	350.00
	$ 17,716.94

*158

1976
Date	Amount
1-19-76	$ 400.00
1-30-76	400.00
3-31-76	400.00
6-3-76	343.53
6-28-76	40.00
6-29-76	343.53
7-27-76	3,100.33
8-24-76	342.48
	$ 5,369.87

Appendix B

1974, 1975 and 1976 Checks Bank of Va. Checking Account No. 7-07158-2 United American/Sparroworld Rev. Cleveland B. Sparrow, Sr., President

	Check	1974
Date	No.	Payee	Amount	Purpose
1-28-74	478	Seat Pleasant Drugs	$ 13.20	RX
2-4-74	482	Perpetual Bldg. Assn.	199.00	Home Mortgage
2-12-74	480	Billy's Valet	16.07	Cleaning
2-13-74	481	Joseph Porter	10.79
2-19-74	484	Division Hardware	13.12
2-19-74	486	Milton Chisley Flower Shop	10.50
2-23-74	490	Charles Datcher Lodge	20.00
2-25-74	492	Vermont Ave. Baptist Church	2.00
2-25-74	493	Vermont Ave. Baptist Church	5.00
3-2-74	494	Robert Hall	41.45	Clothes
3-2-74	495	Kinney	18.71	Shoes
3-7-74	498	Friends-Kennedy Center	7.50
3-12-74	499	Mason's Exxon	15.60
3-12-74	501	Navy, Local #1	21.00	Union Dues
3-27-74	496	L. P. Steuart	164.75
3-29-74	504	Baptist Minister's Wives	22.00
4-13-74	503	American Services	10.80
4-15-74	505	First Baptist church
		("FBC")	4.00
4-22-74	506	Interdenominational
		Minister's Wives	20.00
5-6-74	510	FBC	5.00
5-13-74	517	Vermont Ave. Baptist Church	5.00
5-25-74	512	Hechinger Co.	49.21
6-14-74	523	Virginia Polytechnic
		Institute ("VPI")	60.00
6-16-74	522	FBC	1.00
6-18-74	521	VPI	8.95
6-19-74	524	Civil Air Patrol	8.50
6-25-74	527	FBC	2.00
6-25-74	528	FBC	1.00
6-28-74	531	Mason's Exxon	12.00
6-28-74	532	Harry I. Martin, M.D.	15.00	Doctor
6-28-64	533	Electa Chapter	17.00	Dues
7-7-74	550	Mason's Exxon	10.00
7-14-74	537	FBC	2.00
7-19-74	540	Washington Afro-American	14.00
7-30-74	541	Washington Post	3.35
7-30-74	542	D.C. Treasurer	30.00
7-31-74	544	Mason's Exxon	10.15
8-3-74	546	Capital Hill Art & Frame Co.	8.40
8-3-74	547	Hour of Alert	5.00
8-6-74	548	Jammie's Tire Shop	21.82
8-10-74	551	Mason's Exxon	25.00
8-12-74	552	Mason's Exxon	30.00
8-13-74	554	Mason's Exxon	20.00
8-24-74	558	Billy's Valet	11.73	Cleaning
8-29-74	553	Hechinger Co.	26.32	Cinderblocks
9-2-74	560	Bank of Virginia	20.00
9-11-74	562	Division Hardware	25.72
9-18-74	563	Isaac Kassow, Inc.	$ 22.00
9-18-74	565	Taylor and Son's, Inc.	41.53
9-21-74	566	FBC	2.00
9-29-74	568	FBC	2.00
9-30-74	567	FBC	1.00
10-1-74	569	Mason's Exxon	93.75
10-5-74	570	FBC	2.00
10-9-74	573	Civil Air Patrol	17.00
10-9-74	574	L. P. Steuart Marlowe, Inc.	110.52
10-9-74	592	Keitt Printing Co.	40.00
10-13-74	577	FBC	2.00
10-14-74	576	Baptist Minister's
		Conference	27.00
10-17-74	579	Frank R. Epps	21.33
10-22-74	581	Evan Brown	12.00	Accountant
10-23-74	582	Ruth Turner	15.00
10-23-74	583	Mason's Exxon	8.50
10-25-74	584	Mason's Exxon	24.88
10-25-74	586	Stuart McGuire Co., Inc.	34.90
10-29-74	585	Dr. Walker	15.00	Doctor
11-2-74	588	Billy's Valet	9.18	Cleaning
11-2-74	590	Pursell's Book Store	5.99
11-3-74	591	FBC	2.00
11-9-74	593	Mason's Exxon	20.50
11-10-74	594	FBC	2.00
11-10-74	595	FBC	1.00
11-17-74	596	FBC	2.00
11-17-74	597	FBC	1.00
11-23-74	600	Fred Camp	110.00	TV Repair
11-26-74	601	Dr. West	15.00	Doctor
12-1-74	602	Mason's Exxon	8.40
12-7-74	469	FBC	2.00
12-8-74	603	FBC	1.00
12-13-74	606	VPI	180.00
12-14-74	605	Mason's Exxon	25.49
12-14-74	609	FBC	1.00
12-14-74	610	FBC	2.00
12-16-74	607	Washington Post	5.00
12-16-74	608	Dr. West	15.00	Doctor
12-21-74	613	FBC	2.00
12-23-74	611	Postmaster	10.80	Rental-P.O. Box
12-23-74	614	FBC	1.00
12-30-74	617	Dr. Walker	10.00	Doctor
			$ 1,988.41

		1975
1-3-75	620	Dr. Walker	$ 15.00	Doctor
1-6-75	622	FBC	2.00
1-6-75	623	FBC	1.00
1-7-75	621	Mason's Exxon	7.75
1-13-75	626	FBC	1.00
1-18-75	628	Washington Post	5.00
1-20-75	630	FBC	1.00
1-20-75	631	FBC	2.00
1-21-75	624	Mason's Exxon	21.90
1-24-75	625	Mason's Exxon	10.05
1-25-75	632	The Bookstore	5.00
1-27-75	633	Dr. West	15.00	Doctor
1-27-75	635	D.C. Treasurer	12.00
1-27-75	636	D.C. Treasurer	2.50
1-29-75	637	George Wash. University	67.00
1-29-75	638	Mason's Exxon	20.30
2-6-75	640	Charles Green	12.50
2-7-75	641	Mason's Exxon	7.45
2-8-75	642	1975 Fauntroy Birthday Party	10.00
2-9-75	643	FBC	2.00
2-14-75	645	Mason's Exxon	18.00
2-16-75	644	FBC	1.00
2-16-75	646	FBC	2.00
2-19-75	648	Mason's Exxon	19.00
2-24-75	649	FBC	1.00
2-24-75	650	Rev. Charles Parker	1.00
2-25-75	651	VPI	15.00
2-25-75	652	Adult Education Assn.	10.00
2-25-75	653	Mason's Exxon	25.00
2-26-75	647	Mason's Exxon	12.75
2-28-75	654	Baptist Minister's Wives	5.00
3-1-75	655	Student Bookstore	8.70
3-1-75	656	Mason's Exxon	22.25
3-3-75	657	FBC	2.00
3-3-75	658	FBC	4.00
3-5-75	659	Mason's Exxon	9.75
3-7-75	660	Mason's Exxon	15.00
3-7-75	662	VPI	180.00
3-8-75	663	D.C. Treasurer	53.50	Car tags
3-10-75	664	FBC	2.00
3-11-75	665	Mason's Exxon	18.35
3-12-75	666	D.C. Treasurer	25.00
3-15-75	667	Washington Post	5.00
3-17-75	668	FBC	2.00
3-17-75	669	FBC	5.00
3-20-75	670	Mason's Exxon	9.07
3-23-75	671	FBC	2.00
3-23-75	672	FBC	1.00
3-23-75	673	Rev. Carl Patterson	9.90
3-25-75	676	VPI	45.80
3-26-75	674	Mason's Exxon	2.75
3-29-75	677	Mason's Exxon	31.75	Gas 11.75-Cash 20.00
3-31-75	678	Mason's Exxon	11.85
4-2-75	697	Mason's Exxon	56.25
4-5-75	680	Seat Pleasant Drugs	10.15	RX
4-6-75	681	FBC	2.00
4-6-75	682	FBC	1.00
4-9-75	684	Mason's Exxon	18.50
4-11-75	686	American Fed. Govt.
		Employees	21.00
4-12-75	687	Seat Pleasant Drugs	7.50	RX
4-12-75	688	Ms. Mary Patterson	40.00	Baptist Wives Dinner
4-21-75	690	FBC	2.00
4-21-75	691	FBC	1.00
4-26-75	692	Girl Scouts	5.50
4-28-75	693	FBC	2.00
4-28-75	694	FBC	1.00
5-7-75	698	Mason's Exxon	31.10
5-11-75	701	FBC	1.00
5-11-75	702	FBC	2.00
5-11-75	703	FBC	3.00
5-14-75	696	Mason's Exxon	20.35
5-17-75	704	Charles L. Lee	20.00
5-17-75	706	World Future Society	91.00
5-19-75	707	FBC	2.00
5-19-75	708	FBC	3.00
5-21-75	711	March of Dimes	5.00
5-21-75	712	GEICO	10.85
5-21-75	713	Mason's Exxon	11.00
5-22-75	715	D.C. Treasurer	10.00	Transfer of tags
5-24-75	695	Mason's Exxon	5.00
5-24-75	717	Mason's Exxon	9.75
5-24-75	718	Seat Pleasant Drugs	7.50	RX
5-26-75	701	FBC	2.00
5-28-75	705	Roper Jr. High	6.00	School Trip
5-28-75	706	Mason's Exxon	10.00
5-31-75	707	Mason's Exxon	23.75
6-6-75	711	Mason's Exxon	25.00	Cash
6-8-75	715	Pine St. Baptist Church	5.00	Jr. Choir
6-10-75	713	Seat Pleasant Drugs	17.49	RX
6-10-75	714	Mason's Exxon	33.60
6-14-75	717	Mason's Exxon	5.00
6-14-75	718	Mason's Exxon	5.00
6-19-75	722	Civil Air Patrol	42.75	Uniforms
6-19-75	723	Civil Air Patrol	26.70	Uniforms
6-20-75	720	C&P Tel. Co.	37.00
6-21-75	721	Mason's Exxon	20.00
6-21-75	726	Billy's Valet	17.50	Cleaning
6-22-75	724	FBC	2.00
6-27-75	729	Mason's Exxon	35.10
6-28-75	732	Navy Federal Credit Union	13.00
6-28-75	733	Passport Photos	3.50
7-3-75	734	Navy Federal Credit Union	500.00
7-4-75	742	Mason's Exxon	4.50
7-20-75	737	FBC	1.00
7-20-75	741	FBC	2.00
7-23-75	744	Civil Air Patrol	16.00
7-23-75	745	Civil Air Patrol	6.00
7-26-75	747	Mason's Exxon	16.00
7-27-75	749	FBC	1.00
7-27-75	750	Rehobeth Baptist Church	1.00
7-27-75	751	Rehobeth Baptist Church	1.00
7-28-75	746	Civil Air Patrol	6.00
8-2-75	754	Mason's Exxon	23.60
8-2-75	755	Vermont Ave. Bapt. Church	10.00
8-2-75	756	Vermont Ave. Bapt. Church	10.00
8-2-75	757	Vermont Ave. Bapt. Church	5.00
8-2-75	758	Vermont Ave. Bapt. Church	5.00
8-2-75	759	Vermont Ave. Bapt. Church	5.00
8-2-75	760	Order of Eastern Star	17.00
8-3-75	761	FBC	2.00
8-3-75	762	FBC	1.00
8-10-75	764	FBC	5.00
8-10-75	765	FBC	2.00
8-12-75	782	A. M. West, M.D.	20.00	Doctor
8-16-75	767	Washington Post	5.00
8-17-75	768	FBC	5.00
8-17-75	769	FBC	2.00
8-18-75	770	Roland B. Scott, M.D.	15.00	Doctor
8-18-75	772	GEICO	29.68
8-24-75	774	FBC	2.00
8-24-75	775	FBC	1.00
8-31-75	777	FBC	2.00
8-31-75	778	FBC	1.00
9-3-75	753	Mason's Exxon	7.00
9-3-75	773	Mason's Exxon	35.00
9-8-75	780	Home Mission Board	10.00
9-10-75	781	Schamback Miracle Revivals	5.00
9-13-75	783	Seat Pleasant Drugs	12.75	RX
9-13-75	784	Billy's Valet	11.05	Cleaning
9-13-75	785	Vermont Ave. Bapt. Church	4.00
9-16-75	786	Mason's Exxon	13.00
9-18-75	789	Mason's Exxon	10.00
9-18-75	790	Rev. R. W. Schamback	5.00
9-19-75	791	Rev. R. W. Schamback	2.00
9-19-75	793	Mason's Exxon	15.00
9-19-75	795	Rev. R. W. Schamback	1.00
9-19-75	796	Rev. R. W. Schamback	1.00
9-19-75	797	Rev. R. W. Schamback	1.00
9-21-75	799	Evangel Temple	2.00
9-21-75	800	Evangel Temple	1.00
9-21-75	801	Evangel Temple	1.00
9-21-75	802	Evangel Temple	1.00
9-21-75	805	Rev. R. W. Schamback	25.00
9-21-75	806	12th St. Christian Church	2.00
9-21-75	807	12th St. Christian Church	1.00
9-21-75	808	Rev. E. Gillespie	1.00
9-22-75	803	Mason's Exxon	35.00
9-23-75	810	C&P Tel. Co.	72.16
9-24-75	811	Mason's Exxon	15.00
9-28-75	812	Rehobeth Baptist Church	1.00
9-28-75	813	Rehobeth Baptist Church	1.00
9-28-75	814	Rehobeth Baptist Church	1.00
10-5-75	817	FBC	2.00
10-5-75	818	FBC	1.00
10-5-75	819	Vermont Ave. Bapt. Church	1.00
10-5-75	820	Vermont Ave. Bapt. Church	1.00
10-5-75	821	Vermont Ave. Bapt. Church	1.00
10-8-75	823	Mason's Exxon	14.00
10-8-75	825	Charles Datcher Lodge	40.00
10-10-75	824	VPI	41.85
10-10-75	826	Friends of the Kennedy
		Center	7.50
10-10-75	846	Mason's Exxon	27.30
10-12-75	827	Pine St. Baptist Church	25.00
10-13-75	829	AFGE Local #1	21.88	Union Dues
10-14-75	830	Fairmont Baptist Church	5.00
10-14-75	832	Mason's Exxon	10.50
10-26-75	834	FBC	2.00
10-26-75	835	FBC	1.00
10-26-75	836	St. Mary's Bapt. Church	1.00
10-16-75	837	St. Mary's Bapt. Church	1.00
10-26-75	838	The Celestial Choraleers	10.00	Dinner
11-1-75	842	Mason's Exxon	20.80
11-2-75	843	FBC	2.00
11-2-75	844	FBC	1.00
11-2-75	845	FBC	3.95	Hymnal
11-2-75	847	FBC	2.00
11-11-75	849	Roland B. Scott, M.D.	65.00	Doctor
11-17-75	850	Dr. West, M.D.	39.00	Doctor
11-17-75	851	Petworth Drugs	18.70	RX
11-17-75	853	Roland B. Scott, M.D.	40.00	Doctor
11-21-75	854	Mason's Exxon	26.95
11-22-75	855	Mt. Zion Bapt. Church	10.00
11-23-75	856	FBC	2.00
11-23-75	857	FBC	1.00
11-26-75	859	Navy Federal Credit Union	97.12
12-7-75	862	Rev. Eugene Pearson	1.00
12-8-75	863	FBC	2.00
12-8-75	864	FBC	1.00
12-11-75	867	Yuill Black, M.D.	199.00	Doctor
12-12-75	869	Civil Air Patrol	6.00
12-12-75	870	Civil Air Patrol	6.00
12-12-75	871	Baptist Minister's Wives	5.00
12-12-75	872	WETA	5.00
12-12-75	873	WETA	5.00
12-21-75	875	FBC	2.00
12-21-75	876	FBC	1.00
12-29-75	879	Mason's Exxon	32.50
12-31-75	868	Navy Federal Credit Union	97.12
			$ 3,448.62

		1976
1-2-76	910	Mason's Exxon	11.42
1-5-76	883	Mason's Exxon	8.00
1-8-76	885	VPI	28.90
1-8-76	894	VPI	168.00
1-11-76	891	FBC	2.00
1-11-76	892	FBC	1.00
1-14-76	896	Mason's Exxon	5.00
1-14-76	897	Sidney H. Walker, M.D.	60.00	Doctor
1-15-76	898	Disclosure, Inc.	11.34
1-18-76	900	FBC	1.00
1-19-76	973	COFEPE	2.00
1-25-76	903	FBC	1.00
1-25-76	904	FBC	1.00
1-25-76	906	Washington Post	5.00
1-29-76	902	Mason's Exxon	9.85
1-30-76	913	Baptist Ministers Conference	25.00	1976 & 1977 Dues
1-31-76	912	A. M. West, M.D.	39.00	Doctor
2-1-76	914	FBC	1.00
2-6-76	908	Seat Pleasant Drugs	6.10	RX
2-6-76	917	Mason's Exxon	50.05	Gas & Cash
2-8-76	918	FBC	1.00
2-9-76	909	Mason's Exxon	29.39
2-15-76	920	Brookland Bapt. Church	2.00
2-18-76	919	Mason's Exxon	8.51
2-20-76	922	Navy Federal Credit Union	197.12
2-21-76	921	Billy's Valet	10.50	Cleaning
2-21-76	923	Mason's Exxon	9.20
2-21-76	925	Natl. Baptist Voice	3.00
2-21-76	926	Natl. Baptist Convention	5.00
3-2-76	930	Kohn, Savett	100.00	Discrimination Suit
3-6-76	931	D.C. Treasurer	80.00	Car tags, etc.
3-7-76	932	FBC	1.00
3-7-76	933	FBC	6.00	Senior Choir
3-8-76	929	Mason's Exxon	8.00
3-12-76	934	S. L. Branson	276.00
3-14-76	935	FBC	1.00
3-17-76	936	Mason's Exxon	13.25
3-17-76	937	Civil Air Patrol	24.50
3-25-76	941	Mason's Exxon	30.00
3-26-76	940	Walden University	35.00	Summer 1976
3-27-76	942	Cosmopolitan Secretarial	14.00
3-27-76	944	Mason's Exxon	23.80
3-27-76	945	G.M.U.	2.00
3-28-76	943	Capital View Bapt. Church	2.00
3-31-76	948	VPI	126.00
4-1-76	947	Rehobeth Bapt. Church	12.00
4-4-76	949	Rehobeth Bapt. Church	1.00
4-4-76	950	Rehobeth Bapt. Church	2.00
4-8-76	946	Mason's Exxon	7.00
4-11-76	953	Rehobeth Bapt. Church	1.00
4-11-76	954	Rehobeth Bapt. Church	2.00
4-13-76	951	VPI	16.85
4-15-76	952	Kohn, Savett	100.00	Discrimination suit
4-24-76	955	Harrison McLeod	148.50
4-24-76	956	Oliver Parker	148.50
4-24-76	957	Thomas Turner	50.00
5-9-76	958	FBC	1.00
5-10-76	961	AFGE	26.25	Union Dues
5-12-76	959	Mason's Exxon	21.25
5-21-76	960	WUST	5.00
6-2-76	962	Civil Air Patrol	18.00
6-4-76	964	Mt. Zion Bapt. Church	5.00
6-5-76	965	FBC	2.00
6-5-76	966	FBC	2.00
6-11-76	967	Sidney Walker, M.D.	40.00	Doctor
6-13-76	968	19th St. Bapt. Church	1.00
6-13-76	969	19th St. Bapt. Church	1.00
6-18-76	970	Mason's Exxon	21.35
6-21-76	963	Mason's Exxon	10.00
6-25-76	974	Springer's	247.70	Robe
6-26-76	976	Mason's Exxon	40.00
6-27-76	971	Fairmont Baptist Church	50.00
7-4-76	972	Pine St. Bapt. Church	25.00
7-9-76	975	Mason's Exxon	30.00
7-11-76	979	WUST	108.80	25 min. program
7-12-76	980	Club East Athletic Assn.	40.00
7-13-76	977	Kohn, Savett	100.00	Discrimination Suit
7-18-76	981	New Hope Bapt. Church	1.00
7-18-76	982	New Hope Bapt. Church	2.00
7-24-76	986	U.S. Postmaster	25.00	P.O. Box
7-24-76	987	Civil Air Patrol	19.00
7-24-76	988	Civil Air Patrol	6.00
7-25-76	983	FBC	1.00
7-26-76	985	Mason's Exxon	21.60
8-4-76	990	WUST	100.00	Announcements
8-5-76	989	Mason's Exxon	27.00
8-7-76	984	Scripture Church	5.00
8-8-76	991	James W. Hart	50.00
8-9-76	993	Mason's Exxon	10.25
8-14-76	992	WUST	50.00	Broadcast
8-15-76	997	Vermont Ave. Bapt. Church	70.00	Dues
8-15-76	998	Metropolitan Bapt. Church	2.00
8-21-76	995	WUST	50.00	Broadcast
8-28-76	999	WUST	54.20
9-3-76	722	Insta-Print, Inc.	8.00
9-3-76	996	WUST	55.70	Broadcast
9-4-76	723	Washington Afro	79.20
9-8-76	1001	Natl. Bapt. Convention	25.00
9-8-76	1002	Natl. Bapt. Convention	2.00
9-9-76	1004	Rev. N. Smith	2.00
9-11-76	1005	Concerned Christians	100.00
9-12-76	1007	Lucille R. Miller	300.00	Prayer Breakfast
9-12-76	1008	Baptist Foreign Mission	10.00
9-13-76	724	Instant Passport	10.50
9-17-76	1010	C&P Tel. Co.	43.93
9-17-76	1011	Wall Street Journal	11.18
9-17-76	1013	Washington Hilton	50.00	Prayer Breakfast
9-18-76	1014	Mason's Exxon	26.25	Gas & Cash
9-21-76	1015	American Express	15.72
9-24-76	1017	Washington Hilton	307.00	Prayer Breakfast
9-25-76	1018	Mason's Exxon	25.00
9-25-76	1020	Insta-Print, Inc.	7.25
9-26-76	1023	N.A.A.C.P.	10.00
9-28-76	1019	Mason's Exxon	11.25
9-29-76	1009	Insta-Print, Inc.	8.80
10-2-76	1024	Mason's Exxon	27.60
10-12-76	1006	Washington Hilton	16.12
10-13-76	1025	June Gaskins Davis	75.00
10-15-76	1030	C&P Tel Co.,	37.63
10-17-76	1027	Penna. Ave. Bapt. Church	5.00
10-22-76	1028	Mason's Exxon	4.35
10-24-76	1031	Rehobeth Bapt. Church	1.00
10-24-76	1032	Rehobeth Bapt. Church	12.00
10-24-76	1033	Vermont Ave. Bapt. Church	8.00
10-26-76	1034	American Express Co.	20.89
10-26-76	1036	Washington Afro-American	19.80
10-26-76	1037	Electra Chapter	17.00
10-26-76	1038	Charles Datcher Lodge	20.00	Dues
10-28-76	1029	Mason's Exxon	25.00
10-30-76	1042	Rev. Eugene M. Pearson	10.00
10-31-76	1043	Rev. Charles E. Fields	10.00
10-31-76	1044	Tabernacle Bapt. Choir	2.00
11-1-76	1039	Mason's Exxon	26.00
11-3-76	1040	Columbia Cadet Squad	24.00
11-6-76	1046	Purcell's Religious Books	5.77
11-6-76	1050	Cathedral Choral	10.00
11-7-76	1041	Friendship Bapt. Church	2.00
11-7-76	1047	Rev. B. H. Whiting	7.00
11-7-76	1048	Mt. Zion Bapt. Church	5.00
11-7-76	1049	Friendship Bapt. Church	10.00
11-9-76	1045	Mason's Exxon	25.00
11-12-76	1051	C&P Tel. Co.	15.36
11-18-76	1052	Mason's Exxon	10.85
11-20-76	1053	Mason's Exxon	24.75
11-21-76	1055	FBC	2.00
11-21-76	1056	FBC	1.00
11-21-76	1057	FBC	10.00
11-23-76	1059	Mason's Exxon	29.75
			$ 4,851.83

*159 Appendix C

1974, 1975 and 1976 Checks ¹ RNB Joint Checking Account No. 17-03441557 Cleveland B. Sparrow Joyce S. Sparrow

	Check	1974
Date	No.	Payee	Amount	Purpose
1-7-74	3996	People's Drug Store	$ 15.89	RX
1-10-74	4000	Mason's Exxon	3.00
1-15-74	4003	Harry I. Martin, M.D.	20.00	Doctor
1-21-74	4004	E.L.C.	4.50	TV (Hospital)
1-21-74	4006	C&P Telephone	22.85
1-23-74	4008	E.L.C.	4.50	TV (Hospital)
1-25-74	4009	E.L.C.	2.25	TV (Hospital)
1-29-74	4012	Harry I. Martin, M.D.	10.00	Doctor
2-23-74	4025	Washington Post	2.50
3-9-74	4028	D.C. Treasurer	31.06
3-18-74	4029	C&P Tel. Co.	44.96
3-23-74	4032	D.C. Treasurer	53.50	Car Tags
3-26-74	4033	Harry I. Martin, M.D.	10.00	Doctor
3-28-74	4035	People's Drug Store	12.41	RX
4-10-74	4037	Natl. Bank of Wash.	41.00	Second Trust
4-10-74	4039	C&P Tel. Co.	43.84
4-10-74	4040	A. R. Ugel, M.D. 2	22.00	Doctor
4-12-74	4044	Seat Pleasant Drugs	8.70	RX
4-13-74	4045	A. M. West, M.D.	12.00	Doctor
4-13-74	4046	Billy's Valet	8.93	Cleaning
4-13-74	4050	People's Drug Store	4.31	RX
4-22-74	4054	William H. Seward, M.D.	25.00	Doctor
4-22-74	4055	Seat Pleasant Drugs	5.20	RX
4-25-74	4057	Mason's Exxon	11.20	Gas
4-27-74	4060	Washington Post	2.86
5-7-74	4081	Mason's Exxon	10.50	Gas
5-8-74	4061	Seat Pleasant Drugs	24.40	RX
5-13-74	4064	Vermont Ave. Bapt. Church	1.00
5-20-74	4074	Washington Post	3.10
6-22-74	4099	Billy's Valet	9.03	Cleaning
7-3-74	4107	Mason's Exxon	12.75	Gas 2.75-Cash 10.00
7-8-74	4111	FBC	15.00	Baby Contest
7-13-74	4113	Billy's Valet	9.69	Cleaning
7-15-74	4114	Sidney Walker, M.D.	30.00	Doctor
7-19-74	4122	D.C. Treasurer	17.33
7-19-74	4120	C&P Tel. Co.	34.27
8-2-74	4124	Mason's Exxon	18.90	Gas
8-8-74	4125	Apex Plumber's	6.25	Pipe
8-8-74	4126	Postmaster	10.00	Stamps
8-10-74	4128	Mason's Exxon	20.00	Gas & Cash
8-14-74	4132	Mason's Exxon	10.50	Gas 5.50-Cash 5.00
8-19-74	4137	FBC	1.00
8-19-74	4140	C&P Tel. Co.	53.18
8-21-74	4144	Mason's Exxon	7.40	Gas
8-24-74	4147	Washington Post	3.09
8-26-74	4150	Mason's Exxon	7.40	Gas
8-29-74	4152	The Bookstore	2.50	Books
9-3-74	4153	Mason's Exxon	30.00
9-7-74	4155	Mason's Exxon	10.00	Gas 7.00-Cash 3.00
9-9-74	4157	FBC	1.00
9-18-74	4160	Mason's Exxon	7.30	Gas
9-21-74	4162	Billy's Valet	7.65	Cleaning
9-23-74	4164	FBC	1.00
9-26-74	4168	Mason's Exxon	10.60	Gas
10-3-74	4171	Hechinger Co.	11.63
10-4-74	4173	Washington Post	4.85
10-5-74	4174	Billy's Valet	11.99	Cleaning
10-11-74	4177	Washington Star News	11.60	Advertising
10-12-74	4177	Mason's Exxon	15.21	Gas 10.21-Cash 5.00
10-16-74	4179	Mason's Exxon	10.50	Gas
10-18-74	4181	Billy's Valet	13.77	Cleaning
10-18-74	4182	Mason's Exxon	5.50	Gas
10-23-74	4185	Sidney Walker, M.D.	30.00	Doctor
10-28-74	4189	Washington Post	5.00
11-1-74	4191	Sidney Walker, M.D.	20.00	Doctor
12-6-74	4211	A. M. West, M.D.	15.00	Doctor
12-10-74	4212	Mason's Exxon	8.15	Gas
12-12-74	4217	C&P Tel. Co.	59.75
12-17-74	3965	Audio-Visual Aid	5.00
12-18-74	4219	People's Drug Store	11.99	RX
12-23-74	4226	Mason's Exxon	18.60	Gas 8.60-Cash 10.00
12-30-74	4238	Mason's Exxon	9.20	Gas
12-30-74	4241	United American Appeal	200.00
12-30-74	4243	Participating Bank's
		Loan Fund	30.12
12-31-74	4242	Mason's Exxon	25.00	Cash
			$ 1,320.16

		1975
1-3-75	4244	Seat Pleasant Drugs	$ 13.10	RX
1-9-75	4248	Mason's Exxon	30.75	Gas 10.75-Cash 20.00
1-9-75	4249	Harry Martin, M.D.	15.00	Doctor
1-9-75	4250	Mason's Exxon	10.00	Cash
1-11-75	4252	Mason's Exxon	18.68	Gas 8.68-Cash 10.00
1-14-75	4259	United American Appeal	100.00
1-14-75	4255	D.C. Treasurer	30.49
1-14-75	4258	C&P Tel. Co.	25.68
1-14-75	4260	Mason's Exxon	10.00	Cash
1-14-75	4261	Civil Air Patrol	39.25	Dinner
1-15-75	4262	Mason's Exxon	35.50	Gas 5.50-Cash 30.00
1-18-75	4265	Mason's Exxon	16.90	Gas 11.90-Cash 5.00
1-25-75	4267	Mason's Exxon	14.50	Gas 4.50-Cash 10.00
1-27-75	4270	FBC	1.00
1-27-75	4271	Mason's Exxon	16.00	Gas 6.00-Cash 10.00
1-29-75	4272	Seat Pleasant Drugs	7.50	RX
1-30-75	4273	United American Appeal	140.00
1-30-75	4274	Seat Pleasant Drugs	11.26
2-1-75	4275	Mason's Exxon	12.60	Gas 7.60-Cash 5.00
2-15-75	4287	Mason's Exxon	25.00	Cash
2-22-75	4294	Mason's Exxon	15.40	Gas 5.40-Cash 10.00
2-22-75	4296	Roland Scott, M.D.	15.00	Doctor
2-24-75	4293	United American Appeal	220.00
3-1-75	4302	Billy's Valet	6.63	Cleaning
3-8-75	4304	Mason's Exxon	25.50
3-10-75	4303	United American Appeal	200.00
3-14-75	4313	Roper Jr. High	12.00	Child's Class Ring
3-14-75	4316	C&P Tel. Co.	25.94
3-14-75	4318	A. R. Ugel, M.D.	20.00	Doctor
3-15-75	4319	Mason's Exxon	13.14	Gas 8.14-Cash 5.00
3-20-75	4326	Seat Pleasant Drugs	15.50	RX
3-20-75	4327	Bookstore	8.40
3-21-75	4328	Mason's Exxon	5.00	Cash
3-27-75	4332	Ms. Clyburn	14.00	Girl Scout cookies
4-3-75	4338	The Bookstore	1.00	Sparrow, Jr.
4-5-75	4340	Billy's Valet	8.77	Cleaning
4-12-75	4344	Mason's Exxon	17.00	Gas 7.00-Cash 10.00
4-12-75	4346	Billy's Valet	16.83	Cleaning
4-14-75	4347	United American Appeal	150.00
4-14-75	4348	FBC	1.00
4-15-75	4351	Mason's Exxon	19.45
4-17-75	4352	L. P. Steuart	71.09	Car Repair
4-18-75	4353	Mason's Exxon	21.40	Gas 11.40-Cash 10.00
4-18-75	4354	Sterling Optical	7.95	Frame
4-21-75	4356	FBC	1.00	Youth Choir
4-22-75	4357	Seat Pleasant Drugs	5.20	RX
4-23-75	4358	Merritt School PTA	28.00	Child's School Trip
4-24-75	4365	United American Appeal	75.00
4-24-75	4366	Plumber	12.00	Pipe
4-25-75	4350	Mason's Exxon	10.00
4-28-75	4370	FBC	1.00	Gospel Chorus Day
4-28-75	4371	Mason's Exxon	6.65
5-9-75	4375	Seat Pleasant Drugs	5.20	RX
5-10-75	4377	Mason's Exxon	15.85	Gas 5.85-Cash 10.00
5-17-75	4384	Mason's Exxon	11.25
5-19-75	4387	C&P Tel. Co.	32.44
5-20-75	4386	FBC	1.00
5-21-75	4393	Roper Jr. High	8.50	Cap & gown
6-4-75	4406	Mason's Exxon	21.00	Gas 11.00-Cash 10.00
6-4-75	4408	Mason's Exxon	5.00	Cash
6-6-75	4409	Mason's Exxon	12.30	Gas 7.30-Cash 5.00
6-15-75	4411	Washington Post	5.00
6-16-75	4412	Mason's Exxon	28.50
6-17-75	4415	A. M. West, M.D.	20.00	Doctor
6-18-75	4417	Seat Pleasant Drugs	6.10	RX
6-18-75	4418	Mason's Exxon	7.00
6-19-75	4420	Mason's Exxon	22.35	Gas 7.35-Cash 10.00
6-30-75	4424	Mason's Exxon	10.00
7-3-75	4433	Mason's Exxon	7.75
7-3-75	4434	Seat Pleasant Drugs	10.15	RX
7-7-75	4437	Mason's Exxon	10.00	Cash
7-8-75	4438	GEICO	14.05	Auto Ins.
7-9-75	4439	Civil Air Patrol	15.70	Uniform
7-9-75	4440	Mason's Exxon	8.85
7-11-75	4441	Mason's Exxon	10.00	Cash
7-12-75	4442	Washington Post	5.00
7-14-75	4444	FBC	6.00
7-15-75	4445	Mason's Exxon	16.15	Gas 6.15-Cash 10.00
7-16-75	4449	C&P Tel.	39.74
7-18-75	4453	Mason's Exxon	16.10	Gas 6.10-Cash 10.00
7-18-75	4454	A. M. West, M.D.	20.00	Doctor
7-21-75	4458	Mason's Exxon	10.30
7-27-75	4460	FBC	6.00
7-29-75	4462	D.C. Treasurer	27.86
7-29-75	4464	GEICO	15.34	Car Ins.
8-8-75	4470	Mason's Exxon	5.00
8-9-75	4471	Mason's Exxon	10.20
8-11-75	4354	Mason's Exxon	8.75
8-11-75	4473	Mason's Exxon	15.00
8-15-75	4476	Mason's Exxon	15.00	Gas 10.00-Cash 5.00
8-15-75	4477	Mason's Exxon	5.00	Repairs
8-18-75	4481	Seat Pleasant Drugs	7.45	RX
8-19-75	4484	Mason's Exxon	5.00
8-22-75	4485	Mason's Exxon	5.00
8-22-75	163	Crystal City Music Center	160.00	Stereo
8-23-75	4488	Fred Camp	8.00	TV Repair
8-23-75	4489	Mason's Exxon	8.00
8-24-75	164	FBC	20.00	Trip
8-25-75	4490	Mason's Exxon	5.00	Cash
8-26-75	4492	Mason's Exxon	11.50	Gas 6.50-Cash 5.00
9-5-75	4498	Mason's Exxon	17.80
9-6-75	4500	Mason's Exxon	40.00	Cash
9-8-75	4352	C. Pearson	50.00	Blue Prints
9-15-75	4360	FBC	1.00
9-16-75	4361	International Underwriters	3.75	School Ins.-Child
9-20-75	4363	Washington Post	4.50
9-23-75	4364	Woodson Sr. High	2.25	Gym Locker
9-24-75	4366	D.C. Treasurer	3.50
9-29-75	4374	Mason's Exxon	15.00
9-29-75	4375	VPI	126.00
9-29-75	4376	Dept. Motor Vehicles	12.00
9-30-75	4378	Mason's Exxon	10.00
10-4-75	4377	Mason's Exxon	30.20	Gas 10.20-Cash 20.00
10-10-75	4381	Mason's Exxon	20.00	Gas 10.00-Cash 10.00
10-10-75	4382	A. M. West, M.D.	20.00	Doctor
10-11-75	4417	Peoples Drug	10.74	RX
10-16-75	4386	D.C. Treasurer	3.50
10-17-75	4387	Mason's Exxon	10.00
10-19-75	4390	C&P Tel.	48.45
10-23-75	4398	Roper Jr. High	4.00	Lanita's School Pics
10-23-75	4399	Roper Jr. High	4.00	James' School Pics.
10-24-75	4400	Mason's Exxon	11.55
10-24-75	4401	A. M. West, M.D.	121.00	Doctor
10-25-75	4402	Billy's Valet	11.48	Cleaning
10-26-75	4405	FBC	10.00	Youth Fellowship
				Program
10-31-75	4411	Pursell's book store	10.69	Books
11-1-75	4412	Billy's Valet	14.79	Cleaning
11-15-75	4419	Mason's Exxon	25.55
11-17-75	4427	GEICO	29.68	Car Ins.
11-20-75	4433	Mason's Exxon	13.85	Gas 8.85-Cash 5.00
11-24-75	4441	W. D. Woodson High	20.00	Swimming Team Dues
11-25-75	4442	Colar Inc.	33.00	100 Xmas cards
11-26-75	4443	Mason's Exxon	20.00	Cash
11-26-75	4444	Seat Pleasant Drugs	13.44	RX
11-26-75	4445	Mason's Exxon	50.00	Cash
12-2-75	4448	D.C. Treasurer	3.50
12-4-75	4450	Woodson Booster Club	5.00
12-5-75	4452	Seat Pleasant Drugs	3.60	RX
12-6-75	4453	Mason's Exxon	9.10
12-8-75	4457	Lamp & Shade Center	8.84	Light
12-11-75	4459	Mason's Exxon	11.90
12-12-75	4460	Woodson Band Booster	10.00	Xmas postcards
12-12-75	4461	Woodson High	10.00	Rental-band uniform
12-13-75	4469	Billy's Valet	12.00	Cleaning
12-15-75	4471	FBC	1.00
12-18-75	4473	Mason's Exxon	28.00	Gas 8.00-Cash 20.00
12-20-75	4483	Seat Pleasant Drugs	4.30	RX
12-20-75	4484	Mason's Exxon	18.00	Gas 8.00-Cash 10.00
12-22-75	4524	Atty. Abramson	25.00
12-24-75	4505	Mason's Exxon	21.50	Gas 11.50-Cash-10.00
12-29-75	4506	People's Drug Store	10.00	RX
12-30-75	4508	A. M. West, M.D.	6.00	Doctor
12-31-75	4509	Mason's Exxon	6.41
			$ 3,378.31

		1976
1-9-76	4511	Mason's Exxon	$ 10.00	Cash
1-9-76	4512	D.C. Treasurer	12.00	Renew Permit
1-9-76	4513	Seat Pleasant Drugs	4.25	RX
1-9-76	4510	D.C. Treasurer	3.50
1-10-76	4515	Mason's Exxon	13.90	Gas & Tires
1-12-76	4519	C&P Tel. Co.	30.45
1-17-76	4525	Mason's Exxon	32.40	Gas & Cash
1-17-76	4529	Seat Pleasant Drugs	4.90	RX
2-2-76	4563	H. D. Woodson High	15.00	Trip to Hampton
2-6-76	4539	Leslie L. Williams	11.10	Pictures
2-14-76	4542	Seat Pleasant Drugs	5.20	RX
2-14-76	4651	Mason's Exxon	8.01	Gas
2-16-76	4547	C&P Tel. Co.	41.08
2-16-76	4548	D.C. Treasurer	19.58
2-16-76	4551	Mason's Exxon	5.00	Cash
2-18-76	4554	Seat Pleasant Drugs	27.88	RX
2-20-76	4555	Mason's Exxon	5.00	Cash
2-28-76	4564	Mason's Exxon	40.43	Gas 10.43-Cash 30.00
3-6-76	4569	Mason's Exxon	18.00	Gas 8.00-Cash 10.00
3-6-76	4570	Discount Book Shop	6.48	Book
3-6-76	4571	Seat Pleasant Drugs	19.48	RX
3-10-76	4574	C&P Tel. Co.	67.74
3-12-76	4575	Mason's Exxon	26.90	Gas 6.90-Cash 20.00
3-12-76	4577	A. M. West, M.D.	42.00	Doctor
3-13-76	4582	Wash. Gas Light	68.61
3-14-76	4585	FBC	1.00
3-14-76	4587	Postmaster, Wash. D.C.	13.00	Stamps
3-17-76	4588	Navy Federal Credit Union	97.12
3-19-76	4590	Mason's Exxon	16.15	Gas 6.15-Cash 10.00
3-23-76	4592	Seat Pleasant Drugs	2.34	RX
3-23-76	4593	Washington Post	5.00
3-25-76	4597	American University	2.00	Transcript
3-25-76	4598	Howard University	2.00	Transcript
3-25-76	4599	Virginia Union University	2.00	Transcript
3-25-76	4600	VPI	2.00
4-2-76	4603	Mason's Exxon	18.00	Gas
4-2-76	4604	A. M. West, M.D.	24.00	Doctor
4-3-76	4605	Mason's Exxon	100.00	Cash
4-3-76	4608	Billy's Valet	20.00	Cleaning
4-6-76	4611	Seat Pleasant Drugs	7.75	RX
4-8-76	4616	D.C. Treasurer	75.00
4-10-76	4620	Mason's Exxon	8.15	Gas
4-11-76	4629	Rehobeth Bapt. Church	1.00
4-16-76	4638	Mason's Exxon	20.70	Gas 10.70-Cash 10.00
4-17-76	4641	Navy Federal Credit Union	97.12
4-17-76	4642	Seat Pleasant Drugs	3.95	RX
4-19-76	4647	Seat Pleasant Drugs	7.09	RX
4-19-76	4648	D&W Enterprises, Inc.	85.33	Auto Repairs
4-24-76	4655	Willie Goffins	75.00
4-24-76	4656	Allen Butler	121.50
4-24-76	4657	Jerry Wilson	93.00
4-24-76	4658	Bruce J. Bean	87.00
4-28-76	4662	Woodson Sr. High	12.00	Band Booster
4-28-76	4664	Mason's Exxon	89.30	Car Repair & Cash
4-28-76	4665	Washington Post	5.00
4-28-76	4666	Mason's Exxon	50.00	Cash
4-30-76	4673	Billy's Valet	10.00	Cleaning
4-30-76	4674	Mason's Exxon	11.56	Gas
5-3-76	4676	Mason's Exxon	29.00	Gas & Cash
5-4-76	4677	Seat Pleasant Drugs	11.70	RX
5-4-76	4678	Sports Illustrated	10.92	52 issues
5-6-76	4687	D&W Enterprises, Inc.	16.00
5-6-76	4688	Mason's Exxon	25.30
5-8-76	4696	Mason's Exxon	35.00	Cash
5-10-76	4701	Roper Jr. High	13.00	Trip
5-10-76	4702	Roper Jr. High	15.00	Graduation Pictures
5-10-76	4703	Earl Howard Studios	20.95	Class Ring
5-14-76	4710	A. M. West, M.D.	32.00	Doctor
5-15-76	4712	Mason's Exxon	9.80	Gas
5-17-76	4718	C&P Tel. Co.	39.31
5-19-76	4726	Navy Federal Credit Union	97.12
5-21-76	4740	GEICO	35.40
5-22-76	4733	Mason's Exxon	30.25	Gas 10.25-Cash 20.00
5-22-76	4738	Mason's Exxon	30.00	Cash
5-24-76	4742	Yuill Black, M.D.	51.00	Doctor
5-26-76	4749	Roper Jr. High	13.00	Class Trip
5-27-76	4750	Mason's Exxon	30.00	Gas 10.00-Cash 20.00
5-29-76	4755	Seat Pleasant Drugs	19.15	RX
6-1-76	4758	Mason's Exxon	7.35	Gas
6-1-76	4759	Sidney H. Walker, M.D.	10.00	Doctor
6-2-76	4760	Mason's Exxon	50.00	Cash
6-4-76	4767	Mason's Exxon	20.70	Gas & Cash
6-7-76	4770	Mason's Exxon	10.30	Gas
6-7-76	4772	People's Drug Store	12.63	RX
6-8-76	4774	Commercial Credit Corp.	1,500.00
6-11-76	4777	Mason's Exxon	20.60	Gas 10.60-Cash 10.00
6-14-76	4783	Mason's Exxon	49.25	Gas 9.25-Cash 40.00
6-16-76	4787	C&P Tel. Co.	65.64
6-16-76	4788	D.C. Treasurer	27.55
6-16-76	4790	A. R. Ugel, M.D. ³	20.00	Doctor
6-18-76	4792	Mason's Exxon	20.10	Gas & Cash
6-18-76	4797	American Express Co.	20.00
6-19-76	4799	Mason's Exxon	17.25	Gas 7.25-Cash 10.00
6-23-76	4802	Billy's Valet	11.20	Cleaning
6-23-76	4803	Mason's Exxon	20.00	Cash
6-25-76	4805	Mason's Exxon	9.30	Gas
6-25-76	4806	A. M. West, M.D.	52.00	Doctor
6-28-76	4813	Seat Pleasant Drugs	6.34	RX
6-30-76	4815	Mason's Exxon	10.17	Gas
7-1-76	4819	GEICO	21.74
7-2-76	4820	Mason's Exxon	70.00	Cash for Carpenter
7-3-76	4823	Mason's Exxon	8.35	Gas
7-7-76	4825	Seat Pleasant Drugs	7.75	RX
7-10-76	4828	Mason's Exxon	20.25	Gas 4.25-Cash 16.00
7-14-76	4836	Navy Federal Credit Union	97.12
7-16-76	4842	Mason's Exxon	41.15	Gas 11.15-Cash 30.00
7-17-76	4845	The Hub Furniture Co.	301.84	Furniture
7-17-76	4846	FBC	5.00
7-20-76	4849	Mason's Exxon	17.75	Gas 7.75-Cash 10.00
7-24-76	4858	A. M. West, M.D.	12.00	Doctor
7-24-76	4859	Billy's Valet	15.75	Cleaning
7-24-76	4860	Mason's Exxon	19.55	Gas 9.95-Cash 10.00
7-24-76	4864	C&P Tel. Co.	55.00
7-25-76	4865	Postmaster	13.00	Stamps
7-29-76	4870	Mason's Exxon	15.30	Gas 5.30-Cash 10.00
7-29-76	4874	Drug Fair	5.25	RX
7-31-76	4875	Mason's Exxon	20.40	Gas
7-31-76	4876	Peoples Drug Store	6.34	RX
8-3-76	4878	Montgomery Ward	613.00	Pay off old bill
8-4-76	4881	Homebuilder's Warehouse	10.30
8-6-76	4885	Stephen Epstein, M.D.	20.00	Doctor
8-6-76	4886	Mason's Exxon	20.50	Gas 8.50-Cash 12.00
8-8-76	4887	People's Drug Store	20.79	RX
8-11-76	4894	C&P Tel. Co.	38.75
8-15-76	4897	Metropolitan Bapt. Church	1.00
8-17-76	4903	Mason's Exxon	15.80	Gas 5.80-Cash 10.00
8-17-76	4904	A. M. West, M.D.	23.00	Doctor
8-18-76	4906	GEICO	21.74
8-18-76	4907	Yuill Black, M.D.	28.00	Doctor
8-18-76	4908	C&P Tel. Co.	47.47
8-18-76	4909	Sterling Optical	35.80	Eyeglasses
8-20-76	4912	Mason's Exxon	18.00	Gas 8.00-Cash 10.00
8-21-76	4916	Washington Post	5.00
8-21-76	4920	Mason's Exxon	60.00	Cash for trip
8-25-76	4924	Covington Tire Co.	175.00	Tires
8-28-76	4925	Ray's Transmission	173.58	Repairs
8-29-76	4926	Pine St. Bapt. Church	5.00
9-8-76	4929	Mason's Exxon	27.15	Gas, Oil & Cash
9-11-76	4933	Mason's Exxon	36.00	Gas & Cash
9-13-76	4937	Sterling Optical	35.00	Glasses
9-13-76	4941	Mason's Exxon	31.30	Gas
9-16-76	4942	Atchison & Keller	198.88
9-17-76	4943	Navy Federal Credit Union	97.12
9-17-76	4953	Providence Hospital	39.00	Daughter
9-18-76	4957	Mason's Exxon	10.00	Cash
9-19-76	4960	FBC	2.00
9-21-76	4961	Mason's Exxon	18.00	Gas & Cash
9-22-76	4964	Billy's Valet	20.00	Cleaning
9-22-76	4965	Mason's Exxon	5.00	Gas
9-23-76	4966	H. G. Woodson Swim Team	40.00
9-23-76	4967	H. G. Woodson Band	10.00	Uniform fee
9-24-76	4968	Mason's Exxon	17.40	Gas 7.40-Cash 10.00
9-24-76	4969	Mason's Exxon	20.00	Cash
10-3-76	4975	FBC	1.00
10-4-76	4976	Merritt Elementary School	24.00	Candy
10-4-76	4978	Washington Post	5.00
10-5-76	4979	Mason's Exxon	8.00	Gas
10-6-76	4982	C&P Tel. Co.	73.74
10-9-76	4984	Seat Pleasant Drugs	18.25	RX
10-11-76	4985	Mason's Exxon	40.00	Gas & Cash
10-15-76	4989	A. M. West, M.D.	26.00	Doctor
10-16-76	4991	Mason's Exxon	9.60	Gas
10-16-76	4990	Washington Post	5.00
10-16-76	4992	Billy's Valet	7.50	Cleaning
10-18-76	4997	Navy Federal Credit Union	97.12
10-19-76	4996	Billy's Valet	12.75	Cleaning
10-20-76	5000	Mason's Exxon	10.00	Gas
10-20-76	5001	William H. Seward, M.D.	30.00	Doctor
10-20-76	5002	Better Home & Gardens	6.00
10-20-76	5004	GEICO	21.74
10-23-76	5008	Mason's Exxon	17.15	Gas 7.15-Cash 10.00
10-24-76	5010	Billy's Valet	5.00	Cleaning
10-24-76	5010	Rehobeth Bapt. Church	1.00
10-26-76	5013	Mason's Exxon	4.00	Gas
11-1-76	5043	People's Drug Store	10.81	RX
11-3-76	5020	Johnnie McMichael	70.00	Front Porch
11-4-76	5021	H. D. Woodson High	20.00	Sweatsuit
11-4-76	5023	Mason's Exxon	5.00	Gas
11-6-76	5026	Mason's Exxon	15.00	Gas & Cash
11-7-76	5029	Friendship Bapt. Church	2.00
11-8-76	5031	C&P Telephone	37.51
11-11-76	5034	School Pictures, Inc.	8.50
11-11-76	5035	H. D. Woodson Parents Club	5.00
11-11-76	4880	Mason's Exxon	29.10
11-18-76	5045	Mason's Exxon	20.00	Cash
11-19-76	5048	Navy Federal Credit Union	97.12
11-20-76	5052	Billy's Valet	11.00	Cleaning
11-24-76	5057	Mason's Exxon	20.00	Cash
12-2-76	5062	Mason's Exxon	5.00	Gas
			$ 7,700.24

*160

Appendix D

1974
Schedule A -- Itemized Deductions (Schedule B on back)
Medical and Dental Expenses (not compensated by insurance
or otherwise) (See page 11 of Instructions.)
1	One half (but not more than $ 150) of in-
	surance premiums for medical care. (Be
	sure to include in line 10 below)	$ 150.00
2	Medicine and drugs	107.35
3	Enter 1% of line 15, Form 1040	118.38
4	Subtract line 3 from line 2. Enter
	difference (if less than zero, enter
	zero)	0
5	Enter balance of insurance premiums for
	medical care not entered on line 1	246.61
6	Enter other medical and dental expenses:
	a. Doctors, dentists, nurses, etc.	264.00
	b. Hospitals
	c. Other (itemize -- include hearing aids,
	dentures, eyeglasses, transportation,
	etc.)
7	Total (add lines 4 through 6c)	510.61
8	Enter 3% of line 15, Form 1040	355.15
9	Subtract line 8 from line 7 (if less
	than zero, enter zero)	155.46
10	Total (add lines 1 and 9). Enter here
	and on line 35	$ 305.46
1975
1	One half (but not more than $ 150) of in-
	surance premiums for medical care. (Be
	sure to include in line 10 below)	$ 150.00
2	Medicine and drugs	131.49
3	Enter 1% of line 15, Form 1040	127.59
4	Subtract line 3 from line 2. Enter
	difference (if less than zero, enter
	zero)	3.90
5	Enter balance of insurance premiums for
	medical care not entered on line 1	246.61
6	Enter other medical and dental expenses:
	a. Doctors, dentists, nurses, etc.	252.00
	b. Hospitals
	c. Other (itemize -- include hearing aids,
	dentures, eyeglasses, transportation,
	etc.)
7	Total (add lines 4 through 6c)	502.51
8	Enter 3% of line 15, Form 1040	382.78
9	Subtract line 8 from line 7 (if less
	than zero, enter zero)	119.73
10	Total (add lines 1 and 9). Enter here
	and on line 35	$ 269.73
1976
1	One half (but not more than $ 150) of in-
	surance premiums for medical care. (Be
	sure to include in line 10 below	$ 150.00
2	Medicine and drugs	272.65
3	Enter 1% of line 15, Form 1040	132.77
4	Subtract line 3 from line 2. Enter
	difference (if less than zero, enter
	zero)	139.88
5	Enter balance of insurance premiums for
	medical care not entered on line 1	363.13
6	Enter other medical and dental expenses:
	a. Doctors, dentists, nurses, etc.	409.00
	b. Hospitals
	c. Other (itemize -- include hearing aids,
	dentures, eyeglasses, transportation,
	etc.)
7	Total (add lines 4 through 6c)	912.01
8	Enter 3% of line 15, Form 1040	398.31
9	Subtract line 8 from line 7 (if less
	than zero, enter zero)	513.70
10	Total (add lines 1 through 9). Enter here
	and on line 35	$ 663.70

*161

Footnotes

1. This case was assigned pursuant to sec. 7456(c) (redesignated sec. 7443A by sec. 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755) and Rule 180 et seq. All section references are to the Internal Revenue Code of 1954, as amended and in effect during the years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
Blue Cross made a payment to Dr. Ugel on January 4, 1974 of $ 15.00.
^2↩ Joyce S. Sparrow (hereinafter sometimes referred to as "Ms. Sparrow") did not join in the petition filed herein and, consequently, is not a party to this case.
3. Petitioner also raised the statute of limitations for the taxable years 1974 and 1975 in his petition (see Rule 39). However, he conceded that matter at trial. We observe that the record contains valid and duly executed Consents which extend the period for assessment and collection of income tax due for the years 1974 and 1975 to a date which is beyond the date the notice of deficiency herein was mailed to petitioner and Ms. Sparrow. ↩
4. The Forms W-2, Wage and Tax Statements, reflecting said gross wages and deductions therefrom, which are attached to the returns, are in the record. ↩
5. The Form W-2 for 1974 indicates that additional deductions were made from gross wages for Social Security Hospital Insurance Benefits and for Old-Age Survivor's Disability Insurance but no amounts are shown therefor. Said Forms for 1975 and 1976 do not indicate any such deductions. ↩
6. The great majority of those checks bear a notation thereon as to its purpose. ↩
7. See Appendix C, pps. 35-43, which lists the checks drawn against this account from 1-7-74See Appendix C, pps. 35-43, which lists the checks drawn against this account from 1-7-74 through 12-2-76. through 12-2-76. ↩
8. See Appendix A, pp. 23-24, which lists deposits to this account from 1-4-7See Appendix A, pp. 23-24, which lists deposits to this account from 1-4-7 through X-21-75 through X-21-75. See also Appendix B, pp. 25-27, which lists some 99 checks drawn on this account from X-28-74. See also Appendix B, pp. 25-27, which lists some 99 checks drawn on this account from X-28-74 through X-24-75. through X-24-75. ↩
9. Alter ego is defined as "a second self." Webster, Ninth New Collegiate Dictionary (1983). ↩
10. See Appendix A, p. 24, which lists deposits to the account from X-30-75See Appendix A, p. 24, which lists deposits to the account from X-30-75 through X-24-76 through X-24-76. See also Appendix B, pp. 27-34, which lists some 347 checks drawn on this account from X-25-75. See also Appendix B, pp. 27-34, which lists some 347 checks drawn on this account from X-25-75through XX-23-76. through XX-23-76. ↩
11. A viable corporation and an individual are separate entities. Moline Properties, Inc. v. Commissioner,319 U.S. 436, 438-439↩ (1943).
12. Respondent conceded, at trial, that petitioner would be entitled to a deduction for all charitable contributions he↩ paid in the years at bar, including contributions made to Sparroworld beginning on January 25, 1975.
13. The deduction was reported as contributions made to United American in 1974 and to Sparroworld in 1975 and 1976. ↩
14. This amount is the total of 5 checks written on behalf of United American by petitioner, its president, between January 6, 1975 and January 20, 1975. We have not considered the many checks drawn on behalf of Sparroworld by petitioner, its president, as the account became a corporate account commencing on January 25, 1975. ↩
15. Checks totaling $ 878.77 wee drawn on this corporate account during 1976. We have not considered them. ↩
16. This amount does not include a $ 200.00 check dated December 30, 1974 made payable to United American which is, in effect, a check petitioner wrote to himself. The amounts paid by petitioner's alter ego, United American ($ 140.49) and by petitioner ($ 19.00) in 1974 equal $ 159.49, which is $ 230.51 less than respondent allowed. Since respondent has not sought an increased deficiency we will not disturb his determination. ↩
17. This amount does not include a $ 100.00 check dated January 14, 1975 made payable to United American. The amounts paid by United American ($ 7.00) and by petitioner ($ 834.00) in 1975 equal $ 841.00, which is $ 97.00 greaterr than the amount allowed by respondent. ↩
18. This amount is $ 1,072.00 less than the amount allowed by respondent, however, since he has not sought an increased deficiency we will not disturb his determination for 1976. ↩
19. Sec. 213. ↩
20. There is no probative evidence in the record to support these claimed expenses. ↩
21. Following the same analysis we utilized for charitable deductions, we have considered all medical expenses paid by the petitioner in all years and medical expenses paid by United American beginning on January 1, 1974, and ending on January 24, 1975. We have not considered any medical expense payments paid by Sparroworld from January 25, 1975 through December 31, 1976.↩
22. Since respondent has not sought an increased deficiency we will not disturb his determination. ↩
23. See Appendix D, pp. 44-46, where, based on the probative evidence of record, we have calculated petitioner's allowable medical expense deductions for the years in issue.↩
24. See Form 2106, Employee Business Expenses, appended to each return. ↩
25. Petitioner reported business use of an automobile to be 10,000 miles at $ .15 a mile. ↩
26. Of this amount, $ 794.27 was paid by Sparroworld and, therefore, we have not considered these payments. ↩
27. These payments were paid by Sparroworld and have not been considered.↩
28. These payments for education, as well as those for 1975, were paid by Sparroworld. ↩
29. We can find no check in the record in payment for an education expense in 1974 drawn on the personal account. ↩
30. We note that respondent allowed petitioner travel expense for education for 1975 in the amount of $ 330.00, a year for which no expense was allowed for courses taken, while he allowed petitioner no travel expense for 1974, a year for which he allowed expenses of $ 180.00 for courses taken.↩
31. Respondent advises that he made no determinations under sec. 6651(a), i.e., for late filing, since the tax withheld from petitioner's salary for each year exceeds the income tax deficiency for that respective year. ↩
32. See Stringer v. Commissioner,84 T.C. 693, 703-705 (1985), affd. without published opinion 789 F.2d 917 (4th Cir. 1986); Imhoff v. Commissioner,T.C. Memo. 1979-57, affd. without published opinion 622 F.2d 579↩ (3d Cir. 1980).
33. We wish to emphasize at this point that any charitable contributions paid by Sparroworld in 1975 and 1976 would be deductible by the corporation and not by petitioner. Petitioner adopted the corporate form for purposes of his own. The choice of the advantages of incorporation to do business requires the acceptance of the tax disadvantages. Moline Properties, Inc., supra↩ at 439.
34. Sec. 162(a)↩ reads in relevant part: "There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business * * *."
35. Sec. 6653(a) reads in relevant part:
If any part of any underpayment (as defined in subsection (c)(1) of any tax imposed by subtitle A or by Chapter 12 of subtitle B (relative to income taxes and gift taxes) is due to negligence or intentional disregard of rules and regulations (but without intent to defraud), there shall be added to the tax an amount equal to 5 percent of the underpayment. ↩
36. Petitioner conceded at trial that if the Court finds that additional taxes are due he is liable for these additions to tax. ↩
1. Six checks all dated in 1973 and paid by RNB in 1973 aggregating $ 134.50 were placed in evidence by petitioner. We have disregarded these checks. ↩
3. The record shows that Blue Cross made a payment to Dr. Ugel on March 26, 1976 of $ 36.50. ↩

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1988 T.C. Memo. 99, 55 T.C.M. 335, 1988 Tax Ct. Memo LEXIS 129, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sparrow-v-commissioner-tax-1988.

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