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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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