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See id.
To substantiate additional charitable contributions of
$6,937.20 for 1996 not previously claimed on their return for
that year, petitioners offered several documents to the Court.
Some of the documents do not have any indication of being
provided by a donee organization but instead appear to have been
generated by petitioners. Other documents consist of preprinted
forms issued by alleged charitable organizations which
petitioners filled in with the type and number of items donated
and the estimated value of the donation. In addition,
petitioners submitted checks and receipts which appear to be for
the purchase of goods and services. Lastly, at trial,
petitioners attempted to buttress their claims by describing the
types of goods allegedly donated.
While the preprinted forms appear authentic, we nevertheless
conclude that petitioners’ self-generated receipts and other
documents are not credible evidence of the order necessary to
substantiate the deductions claimed in the instant case. See
Tokh v. Commissioner, T.C. Memo. 2001-45. Further, we do not
find petitioners’ testimony credible. We hold that petitioners
have failed to introduce credible evidence to substantiate the
actual items contributed and their fair market values.4 See sec.
4 For instance, on one of the preprinted forms, petitioners
listed a charitable contribution of $700 for “cribs” and $200 for
“baby clothes”. Because petitioners have failed to establish how
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