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petitioner has furnished no evidence (such as canceled checks or
bank withdrawals contemporaneous with the property acquisition
dates) that would support her cost figures.8 Moreover, because
petitioner’s worksheets were attached to an amended Form 8283
that was furnished to respondent on December 23, 2002, in
connection with the audit, we infer that they were not prepared
contemporaneously with the contributions in 2000, a fact which
casts doubt upon the reliability of those worksheets. See sec.
1.170A-13(a)(2)(i)(A), Income Tax Regs. Under these
circumstances, we find that petitioner’s worksheets are
inadequate to substantiate her claimed deduction for noncash
contributions to L.A. Family Housing in 2000.
Nonetheless, as noted, supra, we are satisfied that
petitioner did donate property to L.A. Family Housing, which
raises the issue as to whether we may use our discretion under
the Cohan rule to find some amount of allowable deduction for the
property donated to L.A. Family Housing. See Cohan v.
Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930), under which we
may estimate the amount of a deductible expense, bearing heavily
against the taxpayer whose inexactitude is of his or her own
8 Even if we were to admit into evidence the printed list
of “suggested price ranges” developed “with the help of Salvation
Army and Goodwill” attached to petitioner’s opening brief (see
discussion, supra), the correlation between the items on that
list and the items on petitioner’s worksheets is unclear.
Moreover, as a list of “suggested” price ranges, that list is not
evidence of the actual value of any particular item.
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