Alonzo Bradley and Emma J. Bradley - Page 9

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          general usage as ordinary clothing; and (3) the uniforms are not            
          so worn.  Yeomans v. Commissioner, 30 T.C. 757, 767-769 (1958).             
               Mrs. Bradley was required to purchase uniforms while she               
          worked as a nurse at Gastroenterology.  However, petitioners have           
          offered no evidence as to whether the uniforms were adaptable to            
          general usage as ordinary clothing.  Thus, respondent's                     
          disallowance of the entire $375 claimed for uniform expenses is             
          sustained.                                                                  
          2.  Charitable Contributions                                                
               Section 170 allows a taxpayer to deduct a charitable                   
          contribution "only if verified under regulations prescribed by              
          the Secretary."  Sec. 170(a)(1).  The regulations provide                   
          specific record-keeping requirements.  With respect to each                 
          charitable contribution of money in a taxable year beginning                
          after December 31, 1982, a taxpayer is required to maintain one             
          of the following:  (1) A canceled check; (2) a receipt or letter            
          from the donee indicating the name of the donee, the date of the            
          contribution, and the amount of the contribution; or (3) any                
          other reliable written record showing the name of the donee, the            
          date of the contribution, and the amount of the contribution.               
          Sec. 1.170A-13(a)(1), Income Tax Regs.                                      
               Petitioners attended, but were not members of, Brentwood               
          Baptist Church (Brentwood) in Houston, Texas.  Of the $4,640                
          deduction for charitable contributions claimed on their 1991                
          return, $4,435 was for contributions to Brentwood.  Petitioners             
          did not substantiate their contributions to Brentwood with                  



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