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contributions made by the taxpayer to a donee organization during
a taxable year equals $250 or more.”
III. Discussion
A. Cash Contributions
1. 2000
On brief, petitioner claims a deduction for “documented”
2000 cash contributions of $4,762. In support of that claim,
petitioner relies on the 2000 Gospel Temple Baptist Church
receipt and a letter, dated December 13, 2004, from West Angeles
Church of God in Christ, attached to her opening brief (the West
Angeles Church of God letter), stating that petitioner
contributed $732 to that church in 2000.3
Because the West Angeles Church of God letter was neither
shared with respondent before trial, introduced in evidence at
trial, or brought to the Court’s attention before the record was
closed, it is not admissible evidence. Attachments to briefs are
not evidence and may not be considered. Rule 143(b); Kwong v.
Commissioner, 65 T.C. 959, 967 n.11 (1976); Perkins v.
3 With respect to the 2000 Gospel Temple Baptist Church
receipt, petitioner concedes, on brief, that the amounts
(totaling $2,300) attributed to “Church Anniversary”, “Pastor’s
Appreciation”, and “Building Fund”, which constitute the proceeds
of fundraisers or benefits organized by petitioner that she
donated to the church, do not constitute deductible
contributions. That leaves total listed contributions of $4,355
($6,655 less $2,300). That amount plus the alleged $732
contribution to West Angeles Church of God in Christ totals
$5,087, which exceeds the $4,762 that petitioner claims is
supported by the documentary evidence of 2000 cash contributions.
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