Herbert J. Meeks and Paula J. Meeks - Page 16

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            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.                    


















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