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of $380. See Cohan v. Commissioner, supra. However, this amount
is subject to the limitations of section 67.
Issue 2. Charitable Contributions
Petitioner testified that he attends church at least once
every week and that he contributed $5 to $10 every Sunday.
Petitioner claimed a deduction on his return for $260 for cash
gifts that he made to the church that he attends. Section 170
allows a deduction for charitable contributions made during the
taxable year. We find that petitioner is entitled to this
deduction. See Cohan v. Commissioner, supra.
Petitioner also claimed a charitable contribution deduction
of $500 for some old clothes and uniforms that he donated to the
Salvation Army. Where a charitable contribution is made in
property other than money, section 170 allows a deduction of the
fair market value of the property at the time of contribution.
See sec. 1.170A-1(c)(1), Income Tax Regs. Petitioner bears the
burden of proving both the fact that the contribution was made
and the fair market value of the contributed property. See Rule
142(a); Zmuda v. Commissioner, 79 T.C. 714, 726 (1982), affd. 731
F.2d 1417 (9th Cir. 1984).
Petitioner offered only a general description of the
articles of old clothing that he donated. While we believe that
petitioner actually did donate some old clothes, petitioner's
testimony that the value of the clothing was $500 was vague and
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