- 13 - 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. SeePage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011