Herbert J. Meeks and Paula J. Meeks - Page 15

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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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