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Welch v. Helvering, 290 U.S. 111, 115 (1933). Moreover,
deductions are strictly a matter of legislative grace, and the
taxpayer has the burden of establishing entitlement to any
deduction claimed on the return. Deputy v. duPont, 308 U.S. 488,
493 (1940); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440
(1934).
The taxpayer's burden of establishing his entitlement to a
deduction includes the burden of substantiation. Hradesky v.
Commissioner, 65 T.C. 87, 90 (1975), affd. per curiam 540 F.2d
821 (5th Cir. 1976). The Court is not bound to accept
unverified, undocumented testimony of the taxpayer. Id.
Accordingly, section 6001 and the regulations promulgated
thereunder require the taxpayer to maintain records sufficient to
enable the Commissioner to determine the taxpayer's correct tax
liability. Meneguzzo v. Commissioner, 43 T.C. 824, 831-832
(1965); sec. 1.6001-1(a), Income Tax Regs.
Petitioners claimed $7,603 of charitable contributions by
cash or check on their 1993 Federal income tax return.
Petitioners substantiated cash and check contributions in the
amount of $4,051, and respondent disallowed the remaining $3,552.
Petitioners have failed to meet their burden regarding the
disallowed contributions by cash or check. Accordingly,
respondent's disallowance of the charitable contributions by cash
or check in the amount of $3,552 is sustained.
Petitioners also claimed $20,138 of charitable contributions
other than by cash or check on their 1993 Federal income tax
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