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The first issue for decision is whether petitioners are
entitled to charitable contribution deductions in excess of the
amounts allowed by respondent for 1993 and 1994.
A taxpayer is required to maintain records sufficient to
establish the amount of his deductions. See sec. 6001; sec.
1.6001-1(a) and (e), Income Tax Regs. In the event that a
taxpayer establishes that a deductible expense has been paid but
is unable to substantiate the precise amount, we generally may
estimate the amount of the deductible expense bearing heavily
against the taxpayer whose inexactitude in substantiating the
amount of the expense is of his own making. See Cohan v.
Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930). We may
estimate a deductible expense only where the taxpayer presents
evidence sufficient to provide some basis upon which an estimate
may be made. See Vanicek v. Commissioner, 85 T.C. 731, 742-743
(1985). Certain expenses related to travel, entertainment,
gifts, and listed property (as defined in section 280F(d)(4)) are
additionally subject to the strict substantiation requirements of
section 274(d). See sec. 274(d); sec. 1.274-5T(b), Temporary
Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).
Section 170(a) allows a deduction for charitable
contributions made during the taxable year to certain listed
types of organizations, if the deductions are verified under
regulations prescribed by the Secretary. See sec. 170(a)(1);
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