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establish entitlement to it. Rule 142(a);1 New Colonial Ice Co.
v. Helvering, 292 U.S. 435, 440 (1934). In order to establish
entitlement to a deduction, the expense to which the deduction
relates must be properly substantiated. Hradesky v.
Commissioner, 65 T.C. 87, 90 (1975), affd. per curiam 540 F.2d
821 (5th Cir. 1976); see also sec. 6001; sec. 1.6001-1(a), (e),
Income Tax Regs. (requiring taxpayers to maintain sufficient
records to permit verification of deductible expenses).
1. Charitable Contribution Deduction
The charitable contribution deduction claimed on
petitioner’s return consists of gifts in cash and property.
According to petitioner, throughout the year in issue he
regularly provided cash in increments from $50 to $800 to his
mother and grandmother who, in turn, donated the cash to a
religious organization. Petitioner testified that he rarely
attended religious services with either his mother or
grandmother. Petitioner also claims to have made cash
contributions to Greenpeace, Toys-For-Tots, the New York City
Fire Department, and the Special Olympics. In addition to the
cash contributions, petitioner claims that he donated property,
1 Petitioner’s failure to substantiate the cost of goods
sold and deductions here in dispute render the provisions of sec.
7491(a)(1) inapplicable. See sec. 7491(a)(2).
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