Lawrence K. and Ruth L. Harrell - Page 7

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         prepared, of items allegedly contributed on December 31, with a              
         value of $850,2 but no receipt for this contribution was produced.           
              The dates on the receipts for January 14 and September 30               
         appear to have been altered, and we are not satisfied that those             
         contributions were in fact made during 2002.  The list of items              
         with respect to the purported December 31 contribution does not              
         support the section 170 deduction because it was prepared                    
         exclusively by petitioners and is therefore not a                            
         “contemporaneous written acknowledgment of the contribution by               
         the donee organization”.                                                     
              The remaining five receipts are supported by detailed lists             
         of items that petitioners allegedly contributed, but the values              
         listed for the individual items do not add up to the total amount            
         claimed for each contribution.  Additionally, the list of items              
         purportedly contributed on June 28 includes a situp table and                
         weights that were also listed in the receipt prepared for the                
         purported January 14 charitable contribution.  And as noted, we              
         are not satisfied that these items in fact were contributed to               
         charity in 2002.                                                             



               2We note that the sums listed on the various receipts                  
          petitioners produced plus the amount on the list of items they              
          allegedly contributed on Dec. 31 is less than the amount claimed            
          for noncash contributions on their 2002 tax return.  Moreover,              
          the values claimed for the individual contributed items listed in           
          the receipts do not total the claimed sum.                                  





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