Darryl R. and Kristi L. Stephens - Page 14




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          a copy of a receipt from The Clothes Less Traveled Thrift Shop,             
          Inc., a charity in Peachtree City, Georgia, for a donation valued           
          at the same amount as the charitable contribution deduction they            
          claimed on the return.  Petitioners’ documentation regarding the            
          donation of property is inconsistent with the position                      
          petitioners took on the return because it lists a different                 
          charity.  Petitioners offered no explanation for this                       
          inconsistency.                                                              
               Mr. Stephens testified that his wife added the dollar value            
          amount to the statement.  Petitioners also introduced several               
          pages of a worksheet they completed to determine that the value             
          of the property they donated was $1,413.  Petitioners introduced            
          no documentation to establish the original purchase price of the            
          property.  We find that petitioners have failed to substantiate             
          and are therefore not entitled to deduct any amount of the                  
          claimed charitable contribution.                                            
               To reflect the foregoing and the concessions of the parties,           


                                                  Decision will be entered            
                                             under Rule 155.                          













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