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“practically new”, he offered no purchase invoices,
documentation, or appraisals on the property to corroborate his
contention.
In the absence of adequate written substantiation, this
Court may, if convinced by the evidence, estimate the amount of
deductible expenses incurred. Cohan v. Commissioner, supra. The
Court is satisfied from the record that petitioner did in fact
make various donations to AMVETS but concludes that the items
were grossly overvalued. Therefore, the Court allows petitioner
a deduction of $750 as a charitable contribution for his
donations to AMVETS.
With regard to the church contributions of $6,239,
petitioner presented a letter from his church attesting to
contributions for that amount. While the Court is satisfied that
petitioner made contributions to his church, the statement does
not list the date or dates of contributions or the manner in
which the payments were made, such as in cash or by check.
Petitioner presented no receipts or canceled checks that would
corroborate the statement of the church. The Court is not
satisfied that petitioner’s contributions to his church amounted
to $6,239 during the 2000 tax year. This amount constituted 22
percent of petitioner’s adjusted gross income for the year and
amounts to $120 per week. The record does not satisfy the Court
that petitioner established payments of that amount for the year.
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Last modified: May 25, 2011