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making. The issue is whether Cohan is applicable in the face of
the statutory admonition of section 170(a)(1) that “[a]
charitable contribution shall be allowable as a deduction only if
verified under regulations prescribed by the Secretary.” Here,
petitioner has not complied with the verification requirements of
section 1.170A-13(b), Income Tax Regs., nor has there been even
substantial compliance with those regulations. (See Bond v.
Commissioner, 100 T.C. 32, 41 (1993), in which we held that the
reporting requirements of the regulations under section 170 are
“directory and not mandatory”, and that substantial (as opposed
to literal) compliance with those regulations is sufficient to
sustain a claimed charitable contribution deduction.) On a
number of occasions, this Court has utilized the Cohan rule to
permit deductions for a portion of claimed charitable
contributions that have not been adequately substantiated. See,
e.g., Fontanilla v. Commissioner, T.C. Memo. 1999-156; Drake v.
Commissioner, T.C. Memo. 1997-487; Cavalaris v. Commissioner,
T.C. Memo. 1996-308; Bernardeau v. Commissioner, T.C. Memo. 1981-
584; Olken v. Commissioner, T.C. Memo. 1981-176. In none of
those cases did we squarely address the potential conflict
between section 170(a)(1) and our application of Cohan to
unverified or inadequately substantiated charitable
contributions. Nor is it necessary to do so in this case,
because the deduction we would be inclined to allow by applying
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