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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
contributions.
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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