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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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