Wayne M. and Janet L. Johnson - Page 10

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               2.  Charitable Contribution Deduction                                  
               Petitioners claimed a charitable contribution deduction in             
          the amount of $2,024 on their 1994 tax return.  Section 170(a)              
          allows as a deduction any charitable contribution which is made             
          within the taxable year.  A charitable contribution is a                    
          contribution or gift to or for the use of an organization                   
          described in section 170(c).  Charitable contributions are                  
          deductible pursuant to section 170 only if verified under                   
          regulations prescribed by the Secretary.  See sec. 170(a)(1).               
               If a charitable deduction 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.               
          See sec. 1.170A-1(c)(1), Income Tax Regs.  Further, any taxpayer            
          who makes a charitable contribution of property other than money            
          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.  See               
          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.             
          See id.; Thorpe v. Commissioner, T.C. Memo. 1998-123.                       
               Petitioner testified that petitioners normally make noncash            
          contributions to Goodwill.  Petitioner provided no specific                 

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