M. Maureen Polsby - Page 8

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          Hradesky v. Commissioner, 65 T.C. 87 (1975).  Thus, we hold that            
          petitioner is not entitled to these claimed deductions.                     
               Section 170(a) allows a taxpayer to deduct charitable                  
          contributions made during the taxable year.  A charitable                   
          contribution is a contribution or gift for the use of an                    
          organization described in section 170(c).  Section 1.170A-                  
          13(a)(1), Income Tax Regs., provides that a taxpayer making a               
          charitable contribution of money must maintain for each                     
          contribution the following:                                                 
                    (i) A cancelled check.                                            
                    (ii) A receipt from the donee charitable organization             
               showing the name of the donee, the date of the contribution,           
               and the amount of the contribution.  A letter or other                 
               communication from the donee charitable organization                   
               acknowledging receipt of a contribution and showing the date           
               and amount of the contribution constitutes a receipt * * * .           
                    (iii) In the absence of a canceled check or receipt               
               from the donee charitable organization, other reliable                 
               written records showing the name of the donee, the date of             
               the contribution, and the amount of the contribution.                  
               The reliability of the written records is to be determined             
          on the basis of all the facts and circumstances of a particular             
          case.  Sec. 1.170A-13(a)(2), Income Tax Regs.  Factors indicating           
          that the written records are reliable include the contemporaneous           
          nature of the writing and the regularity of the taxpayer's                  
          recordkeeping procedures.  Sec. 1.170A-13(a)(2), Income Tax Regs.           
               Petitioner contends that she is entitled to a charitable               
          contribution deduction in the amount of $2,366 (a carryover of              






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