Joseph F. Lisi - Page 6

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          to the extent of his winnings1 of $1,800, and (4) made deductible           
          cash charitable contributions of $600.  Expenses of these types             
          are deductible, if at all, as itemized deductions.  Secs. 62(a),            
          63(d), 165(a), 165(d), 164(a)(1) and (2), 170(a)(1).                        
               A taxpayer must keep records sufficient to establish the               
          amounts of the items required to be shown on his Federal income             
          tax return.  Sec. 6001; sec. 1.6001-1(a), (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.           
          Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930).  We             
          cannot estimate a deductible expense, however, unless the                   
          taxpayer presents evidence sufficient to provide some basis upon            
          which an estimate may be made.  Vanicek v. Commissioner, 85 T.C.            
          731, 743 (1985).                                                            
               Deductions for charitable contribution are subject to                  
          further substantiation requirements.  Sec. 170(a)(1).  Generally,           
          a deduction for charitable contributions must be substantiated              
          with written records.  Sec. 1.170A-13, Income Tax Regs.                     
          Deductions for contributions of $250 or more are disallowed in              


          1Under sec. 165(d), a taxpayer’s losses from gambling are                   
          deductible only to the extent of the taxpayer’s gains from                  
          gambling.                                                                   




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