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his contributions by check, he made no effort to introduce any
canceled checks, bank statements, check registers, or similar
bank-related evidence in support of his claims, offering only
unpersuasive excuses for his failure to do so. The sole church-
related document that petitioner sought to introduce was not
admitted into evidence because it was not found by the Court to
be trustworthy.5
On the other hand, we are satisfied that petitioner made
some church contributions. Accordingly, exercising our
discretion, but bearing heavily against petitioner who bears sole
responsibility for any inexactitude, see Cohan v. Commissioner,
supra, we hold that petitioner is entitled to a deduction for
church contributions in the amount of $250.
2. Other Than by Cash or Check
At trial, petitioner introduced several “receipts”
acknowledging gifts of property. However, petitioner admitted
that, for the most part, he was the person who had filled out the
receipts, describing the condition of the property donated
generally as either “new” or “excellent”, and that he was, in
each instance, the person who had ascribed the monetary value
5 At calendar call, petitioner was expressly advised by the
Court of the importance of calling the church treasurer, business
manager, or similar church individual as a witness to corroborate
his claims if he lacked sound documentary evidence, such as
canceled checks or bank statements. At trial, later that week,
petitioner produced the aforementioned document but called no
witness to support his claimed church donations.
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