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D. Whether Petitioner May Deduct Charitable Contributions for
1998
Petitioner contends that he may deduct charitable
contributions of $2,141 for 1998. More specifically, petitioner
testified that he made weekly donations of $20 to a church, that
his wife made similar weekly contributions, and that his son and
daughter each made weekly contributions of $1.
Respondent contends that he may not deduct any of those
amounts. We agree because petitioner has not substantiated the
contributions as required. See sec. 170(a)(1) (taxpayer must
verify claimed contribution under regulations prescribed by the
Secretary). The Court gave petitioner every opportunity at trial
to offer evidence of his contributions and held the record open
for 4 months to receive evidence, but he provided no evidence of
them. Petitioner did not identify the church to which
contributions were made. See id. Under Cohan v. Commissioner,
39 F.2d 540, 543-544 (2d Cir. 1930), we may estimate the amount
of a deductible expense if a taxpayer establishes that he or she
paid the expense but cannot substantiate the precise amount.
Petitioner’s uncorroborated testimony is the only evidence
supporting his claim. He did not give us an adequate basis to
estimate the amount of his contributions under Cohan. More than
half of the charitable contributions petitioner claims were
attributable to family members and thus are not deductible by
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