Daniela Aldea - Page 5




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          79, 84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435,             
          440 (1934).  Taxpayers are required to maintain records                     
          sufficient to substantiate their claimed deductions.  See sec.              
          6001; sec. 1.6001-1(a), Income Tax Regs.                                    
          Charitable Contributions                                                    
               Section 170(a) allows a deduction for charitable                       
          contributions paid during the taxable year subject to certain               
          limitations.  Deductions for charitable contributions are                   
          allowable only to the extent verified under Treasury regulations.           
          See sec. 170(a)(1).  The applicable regulations require a                   
          taxpayer to maintain for each contribution of money a canceled              
          check, a receipt from the donee organization showing the date and           
          amount of the contribution, or other reliable written records               
          showing the name of the donee and the date and amount of the                
          contribution.  See sec. 1.170A-13(a)(1), Income Tax Regs.                   
               Petitioner has not maintained any of the records required to           
          substantiate her charitable contributions.  She testified at                
          trial that she made cash contributions to Romanian churches:  $80           
          to the New Assembly Church and $1,080 to the First Romanian                 
          Pentecostal Church.                                                         
               The only other evidence of petitioner’s contributions                  
          consists of a 1995 calendar marked with the notation “church” and           
          a dollar amount (usually $20) on each Sunday and two handwritten            
          letters from two different individuals stating that petitioner              







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