- 9 - excess charitable contribution deduction from 1991 of $1,921 plus $445 in cash contributions made in 1992). Although petitioner listed separately the carryover of excess charitable contribution from 1991 and the cash contributions on her Schedule A under Gifts to Charity, for some unexplained reason petitioner did not claim them as a charitable contribution deduction. At trial, petitioner stated that she is entitled to these deductions and an additional charitable contribution deduction for "possessions", including furniture, that she donated to Goodwill in 1992. With respect to petitioner's contention that she is entitled to deduct the carryover charitable contribution from 1991, the $445 in cash contributions, and the additional contributions for "possessions" she donated to Goodwill, the record does not support her claims. The record does not contain any evidence to establish that she was entitled to a charitable contribution deduction carryover. In fact, in direct conflict with the reference to a charitable contribution deduction carryover on her Schedule A, petitioner testified that although she did not exactly remember, she believed that "this $2366, is what was in my check register or slips I had." The record does not contain any reliable written records which show the names of donees, the dates of petitioner's alleged contributions, and the amounts that petitioner purportedly donated. Sec. 1.170A-13(a)(1), Income Tax Regs. We are not required to accept petitioner's testimony asPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011