James W. Taylor - Page 12




                                       - 12 -                                         
          gift to or for the use of listed types of organizations.  A                 
          charitable contribution is allowable as a deduction only if                 
          verified under regulations prescribed by the Secretary.  See sec.           
          170(a)(1).  For charitable contributions of money, taxpayers must           
          maintain for each contribution one of the following:  (1) A                 
          canceled check; (2) a receipt from the donee organization; or (3)           
          other reliable written records.  See sec. 1.170A-13(a)(1), Income           
          Tax Regs.  For charitable contributions of property other than              
          money, taxpayers generally must maintain for each contribution a            
          receipt from the donee showing the following information:  (1)              
          The name of the donee; (2) the date and location of the                     
          contribution; and (3) a description of the property in detail               
          reasonably sufficient under the circumstances.  See sec. 1.170A-            
          13(b)(1), Income Tax Regs.                                                  
               During the trial, petitioner presented an unsigned document            
          entitled, "Quarterly Report of Giving", and a letter from his               
          church.  Both documents are unpersuasive.  The document entitled            
          "Quarterly Report of Giving" was not signed by a church official,           
          even though it provided space for a signature.  The church letter           
          does not even state a definite contribution amount.                         
               Petitioner also claims that he contributed electrical                  
          equipment to Perry Technical Institute and an organization known            
          as "N.P.O.".1  Petitioner has failed to introduce any evidence              


          1    We note that petitioner did not claim a contribution of                
                                                             (continued...)           




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

Last modified: May 25, 2011