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himself when he prepared his tax returns. He offered no receipts
from the donee organization.8 Petitioner stated in the document
he offered that he attended the church three times during the
year and contributed $75 each time. We are convinced that
petitioner attended the church and donated money, but we do not
find the amounts that petitioner claimed to be credible. We may
estimate cash charitable contributions under the Cohan rule. See
Fontanilla v. Commissioner, T.C. Memo. 1999-156. We conclude
that petitioner is entitled to deduct $50 of cash charitable
contributions.
We next turn to petitioner’s contributions of property.
Petitioner provided a Goodwill/Easter Seals tax deduction
statement dated December 24, 2003. Petitioner testified that he
added the dollar value amount to the statement himself.
Petitioner also introduced several pages of a worksheet he
completed when preparing his tax return to determine that the
value of the property he donated was $924. Petitioner reported
8Petitioner argues on brief that cash charitable
contributions of less than $500 do not require a receipt or other
substantiation. Petitioner is incorrect. All charitable
contribution deductions for cash are subject to substantiation.
Sec. 1.170A-13(a)(1), Income Tax Regs. Moreover, deductions for
cash contributions of over $250 are not allowed unless the
taxpayer substantiates the contribution by a contemporaneous
written acknowledgment by the donee organization. Sec.
170(f)(8). All contributions of property are also subject to
substantiation. Sec. 1.170A-13(b), Income Tax Regs. Additional
recordkeeping requirements apply to deductions claimed in excess
of $500 for contributions of property. Sec. 1.170A-13(b)(3),
Income Tax Regs.
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