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Petitioner testified that in an average year he contributed
approximately $100 to the Combined Federal Campaign (CFC) and
that it was possible that he did so in 2003. His practice was to
write a check to CFC, and the reason for his uncertainty about
2003 was his lack of a canceled check. He further stated that he
normally contributes $20 each time he goes to church and that he
probably attended church “maybe three times in 2003.”
Petitioner’s testimony was vague and uncertain.
In general, the regulations require the taxpayer to maintain
one of the following for each contribution of money: (1) A
canceled check; (2) a receipt from the donee; or (3) in the
absence of a check or receipt, other reliable written records.3
Sec. 1.170A-13(a)(1), Income Tax Regs. The taxpayer must
establish the reliability of the written records. Sec. 1.170A-
13(a)(2)(i), Income Tax Regs. Any contribution of $250 or more
shall not be allowed unless the taxpayer substantiates the
contribution by a contemporaneous written acknowledgment of the
contribution by the donee organization.4 Sec. 170(f)(8).
3 Both receipts and reliable written records should include
the name of the donee, the date of the contribution, and the
amount of the contribution. Sec. 1.170A-13(a)(1)(ii) and (iii),
Income Tax Regs.
4 The written acknowledgment must state the amount of cash
and a description (but not necessarily the value) of any property
other than cash the taxpayer donated and also whether the donee
provided any consideration to the taxpayer. Sec. 1.170A-
13(f)(2), Income Tax Regs.
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Last modified: March 27, 2008