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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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