Betty J. Shackelford - Page 26

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               In addition to her deductions for travel expenditures,                 
          petitioner deducted $252 for the Spanish classes that Mr. Maynard           
          took while in Guatemala,13 and $132.60 for parking at the airport in        
          San Francisco during her trip to Guatemala.  We find that                   
          petitioner has not introduced adequate evidence to corroborate her          
          testimony as to the business purpose for these expenditures.                

          Charitable Contribution Deduction                                           

               Next, we must determine whether petitioner is entitled to a            
          deduction for charitable contributions in the amount of $924.               
          Petitioner testified that she contributed "Approximately $1,000 in          
          cash" to the Roseville Church of Christ in addition to the amount           
          that she had already substantiated by canceled checks.  Petitioner          
          claimed that she made weekly cash contributions in addition to her          
          contributions by check, because she did not want the church to know         
          exactly how much she was giving.                                            
               Section 1.170A-13(a), Income Tax Regs., provides certain               
          recordkeeping requirements for charitable contributions:                    

               (1) In general.  If a taxpayer makes a charitable                      
               contribution of money in a taxable year beginning after                
               December 31, 1982, the taxpayer shall maintain for each                
               contribution one of the following:                                     
                    (i) A cancelled check.                                            
                    (ii) A receipt from the donee charitable                          
               organization showing the name of the donee, the date of                
               the contribution, and the amount of the contribution.                  

          13Respondent has conceded that the cost of petitioner's                     
          Spanish classes is a deductible expense.                                    



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