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the year totaling $3,660. Petitioner did not present testimony
with respect to the claimed contributions.
Under certain circumstances, where a taxpayer’s records are
inadequate to substantiate a claimed deduction, we may estimate
the amount. Cohan v. Commissioner, 39 F.2d 540, 544 (2d Cir.
1930). In order for the Court to make an estimate, we must have
some basis in fact upon which an estimate can be made. Williams
v. United States, 245 F.2d 559, 560 (5th Cir. 1957); Vanicek v.
Commissioner, 85 T.C. 731, 742-743 (1985).
While we have some doubt about the reliability of the
contribution receipt and the amount of petitioner’s
contributions, we find that petitioner attended church and made
some contributions to the church in 1997. Bearing in mind that
petitioner has the burden to prove that he is entitled to the
claimed deduction, we hold that petitioner is entitled to an
additional deduction of $800 for donations to the Greater Sunrise
Baptist Church. Thus, petitioner is entitled to a total
charitable contribution deduction of $1,250 for 1997 (including
the $450 previously conceded by respondent).
C. Casualty Loss From Automobile Accident
Petitioner claims a casualty loss of $11,418 for damages
sustained to his 1992 Toyota Camry during an automobile accident
with an insured driver on March 17, 1997. Following the
accident, petitioner filed a claim with the other driver’s
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