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with section 170(f)(8)(B)(ii). However, that receipt, for a
claimed deduction of $4,766, does not contain “[a] description of
the [donated] property in detail reasonably sufficient under the
circumstances”, as required by section 1.170A-13(b)(1)(iii),
Income Tax Regs. See also Castleton v. Commissioner, T.C. Memo.
2005-58. Although it sets forth a list of items (e.g.,
furniture, beds, TV, VCR, dinner set, stove, “old” recorder) and
a total “estimated value” of $5,000, the L.A. Family Housing
receipt contains almost no information regarding the quality,
age, or condition of the donated items that would enable us to
ascertain their value at the time of the donation. Therefore,
there is no evidence that the $5,000 estimated value is accurate
or that it was furnished by the donee rather than by petitioner.7
We also find that petitioner’s worksheets listing the items
allegedly donated to L.A. Family Housing Counsel fail to comply
with the requirement of section 1.170A-13(b)(2)(ii)(D), Income
Tax Regs., regarding the content of a taxpayer’s written records,
that such records state “the method utilized in determining the
fair market value” of the donated property. The only semblance
of a valuation methodology is petitioner’s practice of valuing
each item at less than the alleged cost of that item. But
7 Petitioner’s valuation of the items allegedly donated to
L.A. Family Housing, as set forth in her worksheets attached to
the 2000 amended Form 8283 ($4,766) is close enough to $5,000 to
suggest that that figure was furnished by petitioner rather than
L.A. Family Housing.
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