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petitioners contributed when they went to church on Sundays. He
maintained no records of such contributions. He did not
participate in the church’s envelope system whereby the church
would have a record of his donations. Mr. Coffman estimated that
he gave no less than a $20 bill each time he attended the church.
On the other hand, Mrs. Coffman testified with regard to one
check in the record that it was given to the church because they
did not have any cash at the time. Petitioners have not
indicated the manner in which they determined the total amount
given to the church.
Charitable contributions are deductible under section 170
only if verified under regulations prescribed by the Secretary.
See sec. 170(a)(1). Pursuant to the regulations, contributions
of money are required to be substantiated by one of the
following: (1) A canceled check; (2) a receipt from the donee
charitable organization showing the name of the donee, the date,
and the amount of the contribution; or (3) in the absence of a
canceled check or receipt, other reliable written records showing
the name of the donee, the date, and the amount of the
contribution. See Thorpe v. Commissioner, T.C. Memo. 1998-123;
sec. 1.170A-13 (a)(1), Income Tax Regs. Contributions of
property other than money are required to be substantiated by a
receipt from the donee charitable organization showing the name
and address of the donee, the date and location of the
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