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further that he obtained cash from people that either owed him
money or would lend him money. Thus:
Q: Where did you get the money, the cash money,
that you gave to these preachers and other individuals?
Where would that come from?
A: Well, it would come from a number of sources.
* * * People that owe me money, different people * * *.
You know, I have a number of friends that own tractor-
trailers. I have a number of friends that would tell
me, or I'll lend you the money, because it's something
I really wanted.
Q: They would lend you the money to give to a
charity?
A: Yes. Because if I -- because I had other
plans for my money in the bank.
Q: Even though you had sufficient amounts in your
checking account to cover the check?
A: * * * I had a sufficient amount -- in the
checking account.
Q: But you go and borrow the money, rather than
have them cash the check?
A: Right. Because there are other things I want
to do with it.
We are unable to accept petitioner's testimony at face
value. See Tokarski v. Commissioner, 87 T.C. 74, 77 (1986) (the
Court is not required to accept a taxpayer's testimony as
gospel). Regardless, petitioner's testimony, which was
uncorroborated, does not satisfy the substantiation requirements
of section 170(a)(1) and section 1.170A-13(a)(1) and (b)(1),
Income Tax Regs. Under other circumstances, we might be inclined
to estimate the amount of contributions made by a taxpayer. See
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