Trent Deshawn Allston - Page 10

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          Regs.  Under the applicable provisions, a taxpayer claiming a               
          charitable contribution deduction is required to maintain for               
          each contribution a canceled check, some communication from the             
          donee organization acknowledging receipt of a contribution and              
          showing the date and amount of the contribution, or other                   
          reliable written records showing the name of the donee, along               
          with the date and amount of the contribution.  Sec. 1.170A-                 
          13(a)(1)(i) to (iii), Income Tax Regs.                                      
               At trial, petitioner testified that he regularly made cash             
          contributions to the church where he and his former girlfriend              
          attended services.  He admitted he did not go to church every               
          Sunday but claimed his cash contributions for the year 2002                 
          totaled $3,860.  Additionally, petitioner testified that he                 
          donated two Sony Playstations to the church constituting the $500           
          portion of the charitable contributions made other than by cash             
          or check.                                                                   
               Petitioner did not offer any substantiating documents to               
          support his charitable contributions for the year at issue, nor             
          did he maintain records of the amount of his contributions.                 
          Notwithstanding the Court’s discretionary authority pursuant to             
          Cohan, a taxpayer must provide some basis upon which an estimate            
          of the amount of a claimed deduction may be made.  Vanicek v.               
          Commissioner, supra.  Without such a basis, any allowance would             
          amount to unguided largesse.  Williams v. United States, 245 F.2d           

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