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redecorated their home in 1991 and donated their used furniture
and appliances to the Veterans. The clothing donated in 1991
included petitioner husband's old Marine uniforms. Most of the
1992 contributions consisted of the contents of Mr. Daniel's
deceased parents' home. Mr. Daniel would place the items on the
curb on the day specified by the Veterans who would pick them up.
Section 1.170A-13(b), Income Tax Regs., sets forth the
substantiation requirements for charitable contributions of
property other than money for taxable years beginning after
December 31, 1982. In general, taxpayers must obtain a receipt
from the donee that shows the name of the donee, the date and
location of the donation, and a reasonable description of the
donated property. Sec. 1.170A-13(b)(1), Income Tax Regs. Where
it is impractical to obtain a receipt, taxpayers must maintain
reliable written records of their donations. Id.
Petitioners' offered a receipt from the Veterans as evidence
of their 1991 donations but failed to produce a receipt for their
1992 donations. Petitioners also attached to their 1991 and 1992
returns lists of donated items. After reviewing these lists, we
find that they do not contain all of the information required by
section 1.170A-13(b)(2) and (3), Income Tax Regs. We are
convinced, however, by petitioners' credible testimony and the
information disclosed on the lists that they made donations to
the Veterans in the amounts shown on their returns.
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