- 14 - Commissioner, 40 T.C. 330, 340 (1963). Even though petitioner is a pro se taxpayer, application of that rule in this case is appropriate. The Court, during the trial, specifically advised petitioner: “You can’t add any facts in the brief”, and “Any facts that you want me to consider, you have to tell me right now on the record.” Cf. Clifton-Bligh v. Commissioner, T.C. Memo. 2003-44. Moreover, by failing to state whether West Angeles Church of God in Christ provided any goods or services in consideration, in whole or in part, for what, on its face, appears to be a contribution in excess of $250,4 the letter fails to satisfy the substantiation requirements of section 170(f)(8). See sec. 170(f)(8)(B)(ii). We are satisfied that the 2000 Gospel Temple Baptist Church receipt constitutes a “receipt” for the contributions listed therein. See sec. 1.170A-13(a)(1)(ii), Income Tax Regs. It fails to state, however, whether the church provided any goods or services in consideration, in whole or in part, for those contributions. Because the contribution for “Revival” and each of the 12 monthly contributions are stated to be contributions of $250 or more, all of those contributions fail to meet the requirements of section 170(f)(8)(B)(ii). Therefore, they are 4 The West Angeles Church of God letter contains no breakdown, by amount, of the $732 in total contributions for 2000. Therefore, it does not support a finding that all or any portion of that contribution was in increments of less than $250.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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