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substantiate donations they made and introduced no receipts or
acknowledgment from the church of any contributions. The balance
of the evidence introduced to substantiate petitioners’ cash
contributions relates to Prior Lake Athletics For Youth
(P.L.A.Y.). Mr. Wasik testified that he purchased instructional
videos and kept them at his home, but that he told the other
P.L.A.Y. coaches they were free to use the videos. Mr. Wasik
acknowledged that he did not donate money to the organization.
We are convinced that petitioners attended the church and
donated money. We may estimate such cash charitable
contributions under the Cohan rule.7 See Fontanilla v.
Commissioner, T.C. Memo. 1999-156. We conclude that petitioners
are entitled to deduct $400 of cash charitable contributions to
the church. Petitioners are not entitled to deduct any amount
for cash charitable contributions related to the instructional
videos as they acknowledged they did not make any cash
contributions to that organization. Moreover, we note that
donations must be to the charity. Petitioners may not deduct the
costs of videos they purchased as a charitable contribution
7There are now stricter requirements for contributions of
money. Sec. 170(f)(17). No deduction for a contribution of
money in any amount is allowed unless the donor maintains a bank
record or written communication from the donee showing the name
of the donee organization, the date of the contribution, and the
amount of the contribution. Id. This new provision is effective
for contributions made in tax years beginning after Aug. 17,
2006. Pension Protection Act of 2006, Pub. L. 109-280, sec.
1217, 120 Stat. 1080.
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