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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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Last modified: May 25, 2011