Pepi Schafler, f.k.a. Pepi Summer - Page 14

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               2  Petitioner offered no written substantiation or detailed            
          testimony with respect to these items.                                      

               Section 170(a) allows as a deduction any charitable                    
          contribution which is made within the taxable year.  A charitable           
          contribution is a contribution or gift for the use of an                    
          organization described in section 170(c).  If the contribution is           
          made in property other than money, the amount of the contribution           
          is the fair market value of the property.  Sec. 1.170A-1(c)(1),             
          Income Tax Regs.                                                            
               A taxpayer making a charitable contribution is required to             
          keep a canceled check, a receipt from the donee organization, or            
          some other reliable written record showing the name of the donee,           
          the date of the contribution, and the amount of the contribution.           
          Cavalaris v. Commissioner, T.C. Memo. 1996-308; sec. 1.170A-                
          13(a)(1), Income Tax Regs.  The reliability of a written record             
          is to be determined on the basis of all the facts and                       
          circumstances of a particular case.  Sec. 1.170A-13(a)(2)(i),               
          Income Tax Regs.  Factors indicating that a written record is               
          reliable include the contemporaneous nature of the writing and              
          the regularity of the taxpayer's recordkeeping procedure.  Id.              
               With respect to the claimed charitable contributions listed            
          above as "unspecified", petitioner has offered no reliable                  
          written records or testimony.  Similarly, with respect to the               
          claimed contributions of property, petitioner has offered no                
          reliable written records or testimony to establish that she is              



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