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Petitioner has failed to substantiate entitlement to a theft
loss deduction. In support of his position, petitioner
introduced a handwritten receipt from the purported seller of the
boat and an affidavit from an alleged friend. Neither of these
persons was available at the trial, and petitioner's
documentation is not persuasive. Simply put, we find it
difficult to believe that petitioner purchased a boat, had it
stolen, and then failed to report the theft to the police.
Petitioner's account of this supposed theft lacks credibility and
in the absence of persuasive and admissible corroborating
evidence, we refuse to rely on petitioner's self-serving
testimony. See Niedringhaus v. Commissioner, 99 T.C. 202, 219-
220 (1992); Tokarski v. Commissioner, 87 T.C. 74, 77 (1986).
Based upon the record, we hold that petitioner has not
substantiated a theft loss and is not entitled to a theft loss
deduction.
4. Charitable Contribution
On his 1993 Federal income tax return, petitioner claimed
charitable contributions in cash or check in the amount of
$3,767. Respondent has determined that petitioner has not
substantiated entitlement to a charitable contribution deduction
in an amount greater than $267.
Section 170(a) allows a deduction for charitable
contributions subject to certain limitations. Section 170(c)
defines the term "charitable contribution" as a contribution or
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