James R. and Janet M. Landrum - Page 19

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          amounts claimed as contributions on petitioners’ 1996 and 1997              
          Federal income tax returns.                                                 
               Deductions for charitable contributions are allowable only             
          if verified under regulations prescribed by the Secretary.  Sec.            
          170(a).  Section 1.170A-13, Income Tax Regs., in turn, sets forth           
          the types of substantiation necessary to support deductions for             
          charitable contributions.                                                   
               For charitable contributions of money, taxpayers must                  
          maintain for each contribution one of the following:  (1) A                 
          canceled check; (2) a receipt from the donee organization; or (3)           
          other reliable written records.  Sec. 1.170A-13(a)(1), Income Tax           
          Regs.  Petitioners testified that they regularly made cash and              
          check contributions averaging $50 per week to First Assembly of             
          God in Lawton, Oklahoma.  Petitioners, however, could produce no            
          evidence in support of this claim.  Petitioners testified that              
          they lost the receipts, and that the church did not have any                
          records dating back to either 1996 or 1997.  Petitioners had no             
          canceled checks to substantiate any portion of their alleged                
               We are not required to accept a taxpayer’s uncorroborated              
          testimony at face value if it is improbable, unreasonable, or               
          questionable.  Lovell & Hart, Inc. v. Commissioner, 456 F.2d 145,           
          148 (6th Cir. 1972), affg. T.C. Memo. 1970-335; Tokarski v.                 
          Commissioner, 87 T.C. 74, 77 (1986).  In view of their testimony            

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