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Commissioner, T.C. Memo. 1994-574; sec. 1.170A-13(a)(1), Income
Tax Regs.
If a charitable contribution is made in property other than
money, the amount of the contribution is, generally, the fair
market value of the property at the time of the contribution.
Sec. 1.170A-1(c)(1), Income Tax Regs. Further, any taxpayer who
makes a charitable contribution of property other than money in a
taxable year beginning after December 31, 1982, shall maintain
for each contribution written records from the donee showing the
name and address of the donee, the date and location of the
contribution, and a description of the property in detail
reasonably sufficient under the circumstances. Sec. 1.170A-
13(b), Income Tax Regs. The fair market value of the property is
one of the circumstances to be taken into account in determining
the amount of detail to be included on the receipt. Id.
At trial, with respect to contributions of cash in 1993 and
1994, petitioner offered as evidence schedules which summarize
entries made in her check registers during each of the years 1993
and 1994. The schedules list check numbers, dates on which the
checks were drawn, the names of the various payee organizations,
and the amounts of each check. In conjunction with the summary
schedules, petitioner also submitted as evidence her check
registers from 1993 and 1994, which contain entries that
correspond to the various amounts appearing on the summary
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