David Daniel and Annette Daniel - Page 11

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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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