John William Barck & Janie R. Barck - Page 6




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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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