Karen L. Thorpe - Page 10

                                       - 10 -                                         

          on her 1993 and 1994 Schedules C for her wholesale activity.                
          Therefore, in 1994 petitioner is not entitled to expenses in                
          excess of the $326 for advertising expense and those expenses               
          allowed by respondent in the notice of deficiency.                          
               Petitioner claimed itemized charitable deductions in the               
          amounts of $6,472 and $6,813 for the taxable years 1993 and 1994,           
          respectively.  Respondent disallowed the expenses in the notices            
          of deficiency.  As previously indicated, respondent has conceded            
          a large percentage of these deductions.  Respondent contends that           
          any additional amounts of contributions were not properly                   
          substantiated.  Petitioner now asserts she is entitled to deduct            
          additional amounts not reported on her 1993 Federal income tax              
          return for contributions of property other than money.                      
              Charitable contributions are deductible under section 170              
          only if verified under regulations prescribed by the Secretary.             
          Sec. 170(a)(1).  Under the applicable regulations, contributions            
          of money made in taxable years beginning after December 31, 1982,           
          are required to be substantiated by one of the following:  (1) A            
          canceled check; (2) a receipt from the donee charitable                     
          organization showing the name of the donee, the date, and amount            
          of the contribution; or (3) in the absence of a canceled check or           
          receipt, other reliable written records showing the name of the             
          donee, the date, and amount of the contribution.  Burrell v.                







Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  Next

Last modified: May 25, 2011