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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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