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an organization described in section 170(c)(2). At trial,
respondent conceded the substantiation issue.
OPINION
Section 170(a) allows as a deduction any charitable
contribution, as defined in section 170(c), that is made during
the taxable year. As pertinent here, section 170(c) defines a
charitable contribution as a contribution or gift to or for the
use of a corporation, trust, or community chest, fund, or
foundation which is organized and operated exclusively for
religious purposes, provided that none of the net earnings inures
to the benefit of any private individual. See sec. 170(c)(2);
see also sec. 501(c)(3). Qualified entities under section 170
are essentially those organizations that qualify for an exemption
from tax under section 501(c)(3). See, e.g., Dew v.
Commissioner, 91 T.C. 615, 623 (1988); Kessler v. Commissioner,
87 T.C. 1285, 1288 (1986), affd. without published opinion 838
F.2d 1215 (6th Cir. 1988).
Deductions are a matter of legislative grace and taxpayers
must satisfy the specific requirements of the deductions they
claim. See New Colonial Ice Co. v. Helvering, 292 U.S. 435
(1934). Taxpayers bear the burden of proving their entitlement
to the deductions they claim. See Rule 142(a); INDOPCO, Inc. v.
Commissioner, 503 U.S. 79, 84 (1992); Welch v. Helvering, 290
U.S. 111 (1933); Davis v. Commissioner, 81 T.C. 806, 815 (1983),
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