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amounts of any deductions or credits claimed. Sec. 6001; INDOPCO
Inc. v. Commissioner, 503 U.S. 79, 84 (1992); sec. 1.6001-1(a),
Income Tax Regs.
Generally, the Court may allow for the deduction of a
claimed expense (other than those subjected to the strict
substantiation requirements of section 274) even where the
taxpayer is unable to fully substantiate it, provided the Court
possesses an evidentiary basis for doing so. Cohan v.
Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930); Vanicek v.
Commissioner, 85 T.C. 731, 742-743 (1985); sec. 1.274-5T(a),
Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).
In these instances, the Court is permitted to approximate the
allowable expense, bearing heavily against the taxpayer whose
inexactitude is of his or her own making. Cohan v. Commissioner,
supra at 544.
III. Charitable Contributions
Section 170(a) allows for the deduction of charitable
contributions made to or for the use of an organization described
in section 170(c) and verified as required by the statute and
corresponding regulations. Section 170(f)(8) generally requires
a taxpayer claiming a charitable contribution deduction greater
than $250 to substantiate the deduction by obtaining a
contemporaneous written acknowledgment of the contribution from
the charitable organization. Under section 170(f)(8)(B)(i), that
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