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3. Charitable Contributions
Section 170(a) allows as a deduction a charitable
contribution which is made within the taxable year. As relevant
here, a charitable contribution means a contribution or gift to
or for the use of an organization organized and operated
exclusively for religious, charitable, scientific, literary, or
educational purposes. Sec. 170(c)(2)(B). If a taxpayer makes a
charitable contribution of money the taxpayer shall maintain for
each contribution either a cancelled check, a receipt or letter
from the donee charitable organization, or other reliable written
records showing the name of the donee, the date of the
contribution, and the amount of the contribution. Cavalaris v.
Commissioner, T.C. Memo. 1996-308; sec. 1.170A-13(a)(1), Income
Tax Regs. The reliability of a written record is to be
determined on the basis of all the facts and circumstances of a
particular case. Sec. 1.170A-13(a)(2)(i), Income Tax Regs.
Factors indicating that a written record is reliable include the
contemporaneous nature of the writing and the regularity of the
taxpayer’s recordkeeping procedure. Sec. 1.170A-13(a)(2)(i)(A)
and (B), Income Tax Regs.
If the contribution is made in property other than money,
the amount of the contribution is generally the fair market value
of the property at the time of the contribution. Sec. 1.170A-
1(c)(1), Income Tax Regs. The taxpayer must also maintain a
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