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at issue. Additionally, 1992 was the only year in which
petitioners received any revenue from the chartering activity.
Furthermore, there are elements of personal pleasure present
in petitioners' chartering activity. Petitioners testified that
they would occasionally use the boats for recreational purposes.
Petitioners had also been involved in recreational boating prior
to claiming the activity was a business. This indicates a lack
of profit objective. Sec. 1.183-2(b)(9), Income Tax Regs.
We are not persuaded that the remote and speculative
possibility of profit was petitioners' objective for commencing
their chartering activity. After reviewing all the facts and
circumstances, we conclude that petitioners did not engage in the
chartering activity for profit within the meaning of section 183.
We, therefore, sustain respondent's determination on this issue.
Charitable Contributions
Under section 170(c), contributions of money to or for the
use of a religious organization are generally deductible. Henson
v. Commissioner, T.C. Memo. 1979-110. A taxpayer, however, must
substantiate his contributions. Id.; sec. 1.170A-13(a)(1),
Income Tax Regs. If the record provides sufficient evidence that
petitioners made charitable contributions, but they are unable to
prove the exact amount, we can estimate the amount of the
contributions. Cohan v. Commissioner, 39 F.2d 540, 544 (2d Cir.
1930). In order for the Court to make an estimate, we must have
some basis in fact upon which an estimate can be made. Vanicek
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