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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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