- 17 - to who valued them or what method was used. We find that under the circumstances, considering the nature of the items donated and of the donee institution, the description of the property is reasonable, and petitioner has substantially complied with the requirements of section 1.170A-13, Income Tax Regs. However, petitioner has not provided sufficient substantiation of the fair market value of the property at the time the contribution was made or the method used in determining the value provided on the receipts. Therefore we will not accept his calculation of the amount of claimed deduction. See Bond v. Commissioner, 100 T.C. 32, 41 (1993). Even if we were to exercise our discretion to approximate the value of the contributions and allow petitioner a deduction for the entire amount of noncash charitable contributions claimed, considering our other findings, petitioner would still not be entitled to itemized deductions for 2003 greater than the standard deduction applicable for that year. See Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930); see also Fontanilla v. Commissioner, T.C. Memo. 1999-156; Cavalaris v. Commissioner, T.C. Memo. 1996-308; Bernardeau v. Commissioner, T.C. Memo. 1981-584; cf. Kendrix v. Commissioner, T.C. Memo. 2006-9. Therefore, we decline to exercise our discretion under Cohan.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 NextLast modified: November 10, 2007