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Respondent determined that petitioners did not adequately
substantiate any of their claimed charitable contribution
deduction.
A deduction generally is allowed for any charitable
contribution made within the taxable year. Sec. 170(a)(1).
As previously stated, taxpayers generally must keep records
sufficient to establish the amounts of the items required to be
shown on their Federal income tax return. Sec. 6001; sec.
1.6001-1(a), (e), Income Tax Regs. In the event that a taxpayer
establishes that a deductible expense has been paid but is unable
to substantiate the precise amount, we generally may estimate the
amount of the deductible expense, bearing heavily against the
taxpayer whose inexactitude in substantiating the amount of the
expense is of his own making. Cohan v. Commissioner, 39 F.2d at
543-544. We cannot estimate a deductible expense, however,
unless the taxpayer presents evidence sufficient to provide some
basis upon which an estimate may be made. Vanicek v.
Commissioner, 85 T.C. 731 (1985).
Deductions for charitable contributions are subject to
further substantiation requirements. Sec. 170(a)(1). Generally,
such deductions must be substantiated with reliable written
records reflecting the name of the donee, the date of the
contribution, and either the amount of any cash contribution or a
description of the property contributed. Sec. 1.170A-13(a) and
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