Vashon C. and Beverly C. Jackson - Page 12




                                       - 12 -                                         
                         1990              1991         1992                          
               Claimed   $6,892         $5,300         $5,300                         
               Disallowed     5,419       4,270        4,168                          
               Allowed       1,473        1,030        1,132                          
               Section 170 allows a taxpayer to deduct a charitable                   
          contribution "only if verified under regulations prescribed by              
          the Secretary."  Sec. 170(a)(1).  The regulations provide                   
          specific record-keeping requirements.  See sec. 1.170A-13, Income           
          Tax Regs.  The written evidence submitted by petitioners with               
          respect to their claimed charitable contribution deductions                 
          establishes only a 1992 cash gift in the amount of $275 and a               
          1992 donation of six tennis lessons to the Williams School                  
          located in Norfolk, Virginia.  Petitioners did not submit any               
          other receipts or canceled checks by which the amounts claimed on           
          their returns may be "verified".                                            
              Respondent allowed petitioners charitable contribution                 
          deductions in excess of $1,000 for each of the taxable years in             
          issue.  We find that petitioners have failed to substantiate                
          charitable contributions in excess of the allowed amounts.                  
          Accordingly, we hold that petitioners are not entitled to                   
          charitable contribution deductions in excess of the amounts                 
          allowed by respondent.                                                      
               The fifth issue for decision is whether petitioners are                
          liable for the section 6662(a) accuracy-related penalties.                  








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