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