Jack Lane Taylor - Page 3

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          an organization described in section 170(c)(2).  At trial,                  
          respondent conceded the substantiation issue.                               
               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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