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taxpayer has the burden to prove he or she is entitled to any
deduction claimed. Rule 142(a); Deputy v. du Pont, 308 U.S. 488,
493 (1940); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440
(1934); Welch v. Helvering, supra. This includes the burden of
substantiation. Hradesky v. Commissioner, 65 T.C. 87, 90 (1975),
affd. per curiam 540 F.2d 821 (5th Cir. 1976).
A taxpayer must substantiate amounts claimed as deductions
by maintaining the records necessary to establish he or she is
entitled to the deductions. Sec. 6001; Hradesky v. Commissioner,
supra. The taxpayer shall keep such permanent records or books
of account as are sufficient to establish the amounts of
deductions claimed on the return. Sec. 6001; sec. 1.6001-1(a),
(e), Income Tax Regs. The Court need not accept a taxpayer’s
self-serving testimony when the taxpayer fails to present
corroborative evidence. Beam v. Commissioner, T.C. Memo. 1990-
304 (citing Tokarski v. Commissioner, 87 T.C. 74, 77 (1986)),
affd. without published opinion 956 F.2d 1166 (9th Cir. 1992).
Charitable contributions a taxpayer makes are generally
deductible under section 170(a). No deduction is allowed,
however, for any contribution of $250 or more unless the taxpayer
substantiates the contribution by a contemporaneous written
acknowledgment of the contribution by a qualified donee
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