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property in section 280F(d)(4) is any passenger automobile. Sec.
280F(d)(4)(A)(i).
Thus, under section 274(d), no deduction is allowable for
expenses incurred in respect of listed property such as a
passenger automobile on the basis of any approximation or the
unsupported testimony of the taxpayer. E.g., Golden v.
Commissioner, T.C. Memo. 1993-602. In other words, in the
absence of adequate records or sufficient evidence corroborating
the taxpayer’s own statement, any deduction that is subject to
the stringent substantiation requirements of section 274(d) is
proscribed. These stringent substantiation requirements are
designed to encourage taxpayers to maintain records, together
with documentary evidence substantiating each element of the
expense to be deducted. Sec. 1.274-5T(c)(1), Temporary Income
Tax Regs., 50 Fed. Reg. 46016 (Nov. 6, 1985).
B. Charitable Contributions
1. Gifts by Cash or Check
At trial, petitioner offered only one document that was
admitted into evidence, viz, a receipt dated January 4, 2004,
acknowledging a $50 contribution for 2003 to Feed The Hungry
International of Alexandria, Virginia. We allow this deduction.
Notably, although petitioner claimed to have (1) tithed to
his church and (2) made yet additional contributions to other
churches, and although he claimed to have made at least some of
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