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from the donee charitable organization showing the name and
address of the donee, the date and location of the contribution,
and a description of the property in detail reasonably sufficient
under the circumstances. Sec. 1.170A-13(b)(1), Income Tax Regs.;
see Thorpe v. Commissioner, supra. Where it is impractical to
obtain a receipt, taxpayers must maintain reliable written
records of their donations. Sec. 1.170A-13(b)(1); see Daniel v.
Commissioner, T.C. Memo. 1997-328.
At trial, petitioner alleged that he made donations to the
Unification Church in Mequon, Wisconsin. According to
petitioner, he would deliver a check to the church to be held "as
collateral" for a few days until he came back with cash, at which
time the church would return his check uncashed as a receipt.
The following testimony by petitioner portrays the alleged
arrangement:
I gave it [my check] to the individuals [the clergy] to
hold for me, because they didn't have a check -- a
receipt program of their own. So with my good faith, I
said, Hold the check. I'm going to bring you the money
in just a couple days to help you. Then you can stamp
the check paid that I gave you the money, and I'll take
my check. It will act as our receipt. And that's the
way we did our business like that.
In response to the question why the church did not cash the check
and thereby let the canceled check serve as a receipt, petitioner
testified: "Because I had other plans for my funds in the bank
and I wanted to bring them the cash." Petitioner testified
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