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opinion 166 F.3d 332 (4th Cir. 1998); sec. 1.170A-1(c)(1), Income
Tax Regs.
To be eligible for a charitable contribution deduction for
property, petitioners must, among other requirements, establish
the fair market value of the property at the time of the
contribution and show the method they used to estimate the value.
See Jennings v. Commissioner, T.C. Memo. 2000-366, affd. 19 Fed.
Appx. 351 (6th Cir. 2001); sec. 1.170A-13(b)(2)(ii), Income Tax
Regs. Petitioners attached a form provided by the Salvation Army
upon which petitioners had written the amount of $500. They
presented no detailed information regarding the property, its
cost, or the manner in which the $500 amount claimed as a
deduction was determined.
Respondent disallowed all or part of petitioners' Schedule C
and Schedule A deductions, as well as their "above-the-line"
deduction for self-employment health insurance, because of lack
of substantiation. Petitioners did not keep books and records
which would support an allowance of deductions in excess of the
amounts respondent has already allowed, and they did not produce
any documentary evidence at trial. The only available evidence
as to any of petitioners' expenses in excess of those documented
by canceled checks is petitioner's own self-serving testimony,
which we are not required to accept, and which we do not, in
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