David Daniel and Annette Daniel - Page 10

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            Senior Women's Ministries                                                                    
                  Petitioners submitted statements from Senior Women's                                   
            Ministries of the First Pentecostal Holiness Church that show                                
            petitioners made cash contributions in the amounts of $808 and                               
            $792 during 1991 and 1992, respectively.  These statements were                              
            presented to Ms. Myers during the audit of petitioners' 1991 and                             
            1992 returns.  Ms. Myers testified that she did not contact                                  
            Senior Women's Ministries to verify the documents but nonetheless                            
            disallowed any deductions for the amounts shown.                                             
                  Section 1.170A-13(a)(1)(ii), Income Tax Regs., provides that                           
            taxpayers may substantiate a contribution of money with a                                    
            receipt, letter, or other communication from the donee charitable                            
            organization showing the name of the donee, the date of the                                  
            contribution, and the amount of the contribution.  We find that                              
            the documents introduced by petitioners meet this substantiation                             
            requirement.  We hold that petitioners are entitled to charitable                            
            contribution deductions for their cash donations in the amounts                              
            shown on the statements from Senior Women's Ministries.                                      
            Vietnam Veterans of America                                                                  
                  Petitioners donated furniture, appliances, sporting                                    
            equipment, clothing, and various household goods to the Vietnam                              
            Veterans of America (Veterans) during 1991 and 1992.  Petitioners                            


            4(...continued)                                                                              
            supported the Jamaican church with gifts of cash and donations                               
            in kind.                                                                                     




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