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canceled checks or a receipt from the church. Instead,
petitioners supported their contributions to Brentwood with a
printout of a computer spreadsheet. The spreadsheet indicates
that petitioners attended every Sunday service during 1991,
depositing cash in amounts ranging from $25 to $150 in the
collection plate. Mr. Bradley stated that he would update the
spreadsheet within a day or two of each contribution.
Brentwood records contributions from its members by
supplying envelopes coded with membership numbers to be used by
members when making their weekly offerings. Nonmembers can also
use the envelope system to ensure that Brentwood has a record of
their contributions. Upon entering the church, congregants are
given a worship bulletin and asked by an usher if they would like
an envelope. The ushers who pass the collection plate also carry
envelopes which are readily visible. The congregation is
reminded through the Sunday bulletins, pulpit announcements, and
the monthly membership newsletter to use contribution envelopes
or to retain their canceled checks to receive credit for their
contributions.
Petitioners did not present canceled checks or receipts from
Brentwood, and relied on the written records method of
substantiation instead. The reliability of the records is a
factual determination made on the basis of all relevant facts and
circumstances. Sec. 1.170A-13(a)(2)(i), Income Tax Regs. The
burden of proof is on the donor to establish the reliability of
the written records. Id. On this record, we conclude that
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