Don D. Coffman and Debra Coffman - Page 4




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          contribution, and a description of the property in detail                   
          reasonably sufficient under the circumstances.  See Thorpe v.               
          Commissioner, supra; sec. 1.170A-13(b)(1), Income Tax Regs.                 
          Where it is unrealistic to obtain a receipt, taxpayers must                 
          maintain reliable written records of their contributions.  See              
          Daniel v. Commissioner, T.C. Memo. 1997-328; sec. 1.170A-                   
          13(b)(1), Income Tax Regs.                                                  
               On this record, we hold that petitioners have failed to                
          substantiate any gifts of currency to their church.                         
               The second category of charitable contribution consists of             
          seven checks written by Mrs. Coffman totaling $285, to the                  
          Temescal Canyon High School.  Petitioners’ youngest daughter was            
          a senior at the high school.  In 1995, the parents and school               
          authorities decided to put on a graduation night party in the               
          form of an amusement park.  They secured the services of an                 
          individual who worked for the Disney company, who assisted the              
          various committees in designing items for the party.  Many                  
          parents and neighbors contributed to this function.  The students           
          who attended this function had to pay an admission fee, but                 
          petitioners’ substantiation does not include any payment for                
          admission.  Basically, petitioners and other parents were                   
          spending money to fund a graduation party for the seniors.  Their           
          purpose of using the amusement park theme to prevent “partying              
          and drinking” by the graduates is commendable, but it does not              





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