Timothy E. Butler - Page 11

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          dependent for the taxable year but for section 152(a)(9).  Sec.             
          2(b)(3)(B)(i).                                                              
               We have previously held that petitioner is not entitled to             
          dependency exemptions for Lynn, Bob, and Robin in 1993 and for              
          James in 1994.  Accordingly, petitioner does not qualify as a               
          head of household.  However, even if we had held that petitioner            
          is entitled to dependency exemptions under section 152(a)(9),               
          petitioner would still not qualify, as a matter of law, as a head           
          of household because of the limitation set forth in section                 
          2(b)(3)(B)(i).  Accordingly, we sustain respondent's                        
          determination that petitioner is not entitled to head of                    
          household filing status but rather "single" filing status.                  
               Issue (3): Charitable Contributions - 1993 and 1994                    
               Charitable contributions are deductible under section 170              
          only if verified under regulations prescribed by the Secretary.             
          Sec. 170(a)(1).  Under the applicable regulations, contributions            
          of money are required to be substantiated by one of the                     
          following: (1) A canceled check; (2) a receipt from the donee               
          charitable organization showing the name of the donee, the date,            
          and amount of the contribution; or (3) in the absence of a                  
          canceled check or receipt, other reliable written records showing           
          the name of the donee, the date, and amount of the contribution.            
          Sec. 1.170A-13(a)(1), Income Tax Regs.; see Thorpe v.                       
          Commissioner, T.C. Memo. 1998-123.  Contributions of property               
          other than money are required to be substantiated by a receipt              




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