Craig E. and Debbie A. Brown - Page 12

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          contributions of cash, a taxpayer shall maintain for each                   
          contribution a canceled check or receipt from the donee                     
          indicating the name of the donee, the date of the contribution,             
          and the amount of the contribution, or in the absence of a check            
          or receipt from the donee, reliable written records showing the             
          name of the donee, the date of the contribution, and the amount             
          of the contribution. Sec. 1.170A-13(a)(1), Income Tax Regs.                 
               Petitioner testified that he made cash and check                       
          contributions to CASC and that he believed in tithing. Eugene               
          Brown testified that petitioner made contributions to CASC, but             
          could not testify as to specific dates or amounts. However, he              
          did testify that the church maintained records pertaining to                
          contributions, that he did not bring those records to the trial,            
          and that petitioner did not request him to do so. Petitioner                
          attempted to remedy this lack of evidence by attaching to his               
          reply brief several documents purporting to verify his charitable           
          contributions to CASC. Evidence must be submitted at trial.                 
          Documents attached to briefs and statements made therein do not             
          constitute evidence and will not be considered by the Court. Rule           
          143(b); Evans v. Commissioner, 48 T.C. 704, 709 (1967), affd. per           
          curiam 413 F.2d 1047 (9th Cir. 1969); Lombard v. Commissioner,              
          T.C. Memo. 1994-154, affd. without published opinion 57 F.3d 1066           
          (4th Cir. 1995); Pauli v. Commissioner, T.C. Memo. 1984-591.                
               According to the testimony of Art Glass, PH members are                
          requested to donate $120 per year. Petitioner presented no                  




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