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must also keep sufficient records to substantiate any deduction
that would otherwise be allowed by the Code. Sec. 6001;
New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934).
With respect to the $3,000 charitable contribution reported
on her 1993 Form 1040, petitioner argues that she is entitled to
deduct this amount on account of a $3,000 donation to B-Ball in
1993. Petitioner relies solely on her testimony to support her
claim to this deduction.
We find petitioner's testimony inconsistent and
unpersuasive. Petitioner testified that she paid "approximately
$3,000" to B-Ball; however, she was unable to state unequivocally
when she purportedly paid this amount. Petitioner testified that
she was unsure whether she paid the $3,000 amount in one or
several installments. Petitioner later testified that she had
$3,000 in cash when she attended a B-Ball meeting, and that she
gave it to one of B-Ball's representatives at that time.
Petitioner's lack of detailed books, records, and receipts
precludes the Court from reaching a determination of what (if
anything) was given to B-Ball. Even if we could arrive at such a
determination, petitioner would still not be entitled to the
disputed deduction. Petitioner has not proven that B-Ball was a
qualified recipient under section 170(c)(2).2 See McGahen v.
2 Although petitioner does not argue that she can deduct the
$3,000 amount given to the Most Worshipful United Grand Lodge
(continued...)
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