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deduction even without written records where a taxpayer provides
a sufficient basis to estimate the amount of the contributions,
such as showing regular church attendance and regular cash
contributions thereto. See, e.g., Fontanilla v. Commissioner,
T.C. Memo. 1999-156; Meeks v. Commissioner, T.C. Memo. 1998-109,
affd. 208 F.3d 221 (9th Cir. 2000); Drake v. Commissioner, T.C.
Memo. 1997-487. Petitioner attended church every Sunday and
often donated cash, even when he traveled. However, he failed to
establish any regularity in occurrence or extent of the donations
from which we could estimate an amount. Thus, petitioners are
not entitled to a charitable contribution deduction for 1993 in
excess of $6,397.
The amounts disallowed in 1994 all relate to contributions
made to Eugene Brown. Mr. Brown served as president of the Full
Gospel Business Men’s Fellowship International (FGBMFI). The
disallowed contributions consist of an automobile which they
valued at $5,000 and cash of $335 in the form of checks made
payable to the order of Gene Brown. Petitioners testified that
the car was given to FGBMFI. However, the car was titled solely
in Mr. Brown’s name. In addition, Mr. Brown provided a
handwritten statement that the car was given to him as a gift by
petitioner. Despite petitioners’ testimony, it is clear that the
car was transferred from petitioners to Mr. Brown individually
and not to the charitable organization. Thus, the disallowed
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