- 8 - 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 ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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