Timothy E. Butler - Page 13

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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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