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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.
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