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purposes, or for the prevention of cruelty to animals. Sec.
170(c)(4). Petitioner has failed to establish that these
donations were used exclusively for the purposes specified in
section 170(c)(4). Additionally, she has failed to establish
that the amounts she paid for these events exceed the fair market
value she received. Furthermore, payments for raffle tickets
generally do not qualify as charitable contributions. Goldman v.
Commissioner, 46 T.C. 136 (1966), affd. 388 F.2d 476 (6th Cir.
1967).
If a taxpayer makes a charitable contribution of money, the
taxpayer must maintain for each contribution either (1) a
canceled check, (2) a receipt from the donee organization, or (3)
other reliable written records. Sec. 1.170A-13(a)(1), Income Tax
Regs. Although petitioner did provide the Court with many checks
and receipts, these items do not support her claims. The
receipts and checks provided by petitioner show amounts paid to
fraternal organizations. Some receipts lack the payee's name.
As discussed above, petitioner has failed to establish that these
amounts were donated for a charitable purpose. Petitioner has
not provided us with sufficient documentation to substantiate the
charitable contribution deductions she claimed on her 1993 and
1994 Federal income tax returns.
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