- 16 - v. Commissioner, 85 T.C. 731, 743 (1985). Without such a basis, any allowance would amount to unguided largesse. Williams v. United States, 245 F.2d 559, 560 (5th Cir. 1957). The burden is on petitioners to prove their entitlement to the claimed deductions. Rule 142(a). In this case, petitioners credibly testified and we find that they did make cash contributions to the churches they attended. However, we are cautioned to bear heavily against taxpayers whose inexactitude is of their own making. Cohan v. Commissioner, supra at 544. Accordingly, we hold that petitioners are entitled to deduct $3,375 and $725 of their claimed charitable contributions for 1992 and 1993, respectively, in excess of the amounts allowed by respondent. To reflect the foregoing and concessions of the parties, Decisions will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16
Last modified: May 25, 2011