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that amount. Petitioner's unchallenged testimony at trial was
that he purchased the same amount of lottery tickets each week,
at a cost of approximately $80 per month, and that he began
saving his (losing) tickets after he won the $1,000 in March
2000. The $851 total for the tickets purchased from March
through December 2000 corroborates petitioner's testimony.
Petitioner's testimony is unimpeached and should not be
disregarded. See Loesch & Green Constr. Co. v. Commissioner, 211
F.2d 210, 212 (6th Cir. 1954). We accordingly conclude that
petitioner has provided reasonable evidentiary support for
invocation of the Cohan rule, and find that he had additional
gambling losses of $160 in January and February of 2000. See
Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930);
Vanicek v. Commissioner, 85 T.C. 731, 743 (1985). These losses
fully offset the gambling winnings for 2000, but are not further
deductible. See sec. 165(d); see also Offutt v. Commissioner, 16
T.C. 1214 (1951).
B. Charitable Contribution Deductions
Section 170 provides that charitable contributions may be
deducted from gross income "if verified under regulations
prescribed by the Secretary". Under the regulations, a taxpayer
must maintain records of each contribution, such as a canceled
check, a receipt, or other reliable records from the charitable
organization. Sec. 1.170A-13(a)(1), Income Tax Regs.
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