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organization.6 Sec. 170(f)(8)(A). The deduction for a
contribution of property equals the fair market value of the
property on the date contributed. Sec. 1.170A-1(c)(1), Income
Tax Regs.
A taxpayer claiming a charitable contribution deduction is
generally required to maintain for each contribution a canceled
check, a receipt from the donee charitable organization showing
the name of the organization and the date and amount of the
contribution, or other reliable written records showing the name
of the donee and the date and amount of the contribution. Sec.
1.170A-13(a)(1), Income Tax Regs.
Petitioners assert they are entitled to a charitable
contribution deduction. Petitioners reported on the return for
2003 that they acquired personal property on January 1, 1920,7
for $2,000, which they donated to the Salvation Army in
Minneapolis, Minnesota. At trial, however, petitioners provided
6There are now stricter requirements for contributions of
money. Sec. 170(f)(17). No deduction for a contribution of
money in any amount is allowed unless the donor maintains a bank
record or written communication from the donee showing the name
of the donee organization, the date of the contribution, and the
amount of the contribution. Id. This new provision is effective
for contributions made in tax years beginning after Aug. 17,
2006. Pension Protection Act of 2006, Pub. L. 109-280, sec.
1217, 120 Stat. 1080.
7We assume petitioners made an error on Form 8283, Noncash
Charitable Contributions, when they claimed that they acquired
the property they donated on Jan. 1, 1920, a date before
petitioners were born.
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