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the amount of $3,660 for contributions to the Greater Sunrise
Baptist Church.
Section 170 allows a deduction for charitable contributions
made for religious purposes. For contributions of money,
taxpayers must maintain canceled checks, receipts from the donee
organizations showing the date and amounts of the contribution,
or other reliable written records showing the name of the donee,
date, and amount of the contribution. See sec. 1.170A-13(a)(1),
Income Tax Regs. Petitioner bears the burden of proving he is
entitled to deductions claimed. See Rule 142(a); New Colonial
Ice Co. v. Helvering, 292 U.S. 435, 440 (1934).
Petitioner produced a photocopy of a “contribution receipt”
from the Greater Sunrise Baptist Church dated December 30, 1997,
showing contributions in 1997 of $3,660.5 The receipt was
generated by a computer word processing program and was not
printed on an official letterhead of the church. The photocopy
bears the purported signature of “Rev. A.W. Crowder” and contains
the purported stamped seal of the church. It is unclear from the
receipt whether petitioner donated the entire $3,660 on December
30, 1997, or whether petitioner made periodic donations during
5 The receipt was submitted to the Court by a posttrial
Supplemental Stipulation of Facts. Respondent objected to the
admissibility of the receipt on the ground of authenticity. We
overrule that objection and admit the receipt as we conclude that
the receipt has some probative value. See Rule 174(b).
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