- 11 - 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 receiptPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011