Thomas M. and Dolores F. Gomez - Page 10

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               Section 1.170A-13(a), Income Tax Regs., provides that, if a             
          contribution of money is made in a taxable year beginning after              
          December 31, 1982, the taxpayer shall maintain, for each                     
          contribution, one of the following:                                          
               (1) A canceled check;                                                   
               (2) a receipt, letter, or other communication from the                  
          donee charitable organization acknowledging receipt of the                   
          contribution and showing the name of the donee, the date of the              
          contribution, and the amount of the contribution; or                         
               (3) in the absence of a canceled check or receipt from the              
          donee organization, other reliable written records showing the               
          name of the donee and the date and amount of the contribution.               
               In addition, the taxpayer must establish the reliability of             
          the written records.  See sec. 1.170A-13(a)(2)(i), Income Tax                
               Petitioners have the burden of proving their entitlement to             
          the charitable deductions claimed.  See Rule 142(a).  To do so,              
          petitioners must substantiate their charitable contributions.                
          See sec. 6001; Brown v. Commissioner, T.C. Memo. 1996-43; Paige              
          v. Commissioner, T.C. Memo. 1994-638.  In this case, petitioners             
          did not substantiate the charitable contributions claimed on                 
          their 1993 return in excess of those allowed by respondent.                  
          Petitioners kept no records regarding their 1993 contributions.              
          In addition, petitioner's testimony regarding petitioners'                   
          charitable deductions was not credible.  Petitioner testified at             
          trial that petitioners made a cash contribution of $5,000 to La              

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