- 9 - dispute involves only (1) the valuation of clothing donated to Crossnore School, and (2) unreimbursed travel expenses claimed by petitioner. Respondent does not dispute the tax exempt status of any of the organizations involved. 1. Crossnore School Deduction Section 170(a) allows a deduction for charitable contributions. If the contribution is made in property other than money, the amount of the contribution is the fair market value of the property. Sec. 1.170A-1(c)(1), Income Tax Regs. On his 1990 Federal income tax return petitioner claimed a charitable contribution deduction in the amount of $1,000 for clothing donated to Crossnore School. A handwritten list of the items donated filled the majority of a sheet of looseleaf paper. The items of greatest value on the list include eight three-piece suits, four sport coats, one tuxedo, two overcoats, four pairs of shoes (one new), one leather coat, and two pairs of lizard skin boots. Respondent determined that the fair market value of the property was $353. Petitioner's testimony focused on the cost of some of the items but, with the exception of the new shoes, no evidence was introduced to show the condition or the fair market value of the property. Accordingly, we conclude petitioner has failed to meet his burden of proving that the fair market value of the donated items was $1,000. On the other hand, we conclude that the valuePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011