Myer B. Barr and Estate of Diana L. Barr - Page 11

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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            
               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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