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Petitioners contend that they made substantial charitable
cash contributions in 2003 to St. Jude’s Hospital, Texas
Christian University, and both their church and the churches of
their friends, which they attended occasionally. Petitioners did
not provide any receipts, canceled checks, or other written
records for their claimed contributions. Petitioner testified
that he did not have receipts for the contributions that
petitioners made to churches because he did not want to ask the
pastor of the church to provide him with a receipt for tax
purposes. Although petitioners did not provide a receipt for
their contribution to Texas Christian University, petitioner
testified that he has been a regular contributor to Texas
Christian University for many years and is familiar with the
donation process there.
Based on the foregoing, we are convinced that petitioners
have not established either that they made the contributions
purported or that the value of such contribution was $17,889.
Moreover, we note that although petitioners could have easily
obtained the necessary documentation to support most of the cash
contributions that they purportedly made in this case, they did
not do so.
Accordingly, because petitioners have failed to comply with
the requirements under section 170(a) with respect to noncash
contributions and have failed to substantiate any of the claimed
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Last modified: November 10, 2007