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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 value
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