- 4 - contribution, and a description of the property in detail reasonably sufficient under the circumstances. See Thorpe v. Commissioner, supra; sec. 1.170A-13(b)(1), Income Tax Regs. Where it is unrealistic to obtain a receipt, taxpayers must maintain reliable written records of their contributions. See Daniel v. Commissioner, T.C. Memo. 1997-328; sec. 1.170A- 13(b)(1), Income Tax Regs. On this record, we hold that petitioners have failed to substantiate any gifts of currency to their church. The second category of charitable contribution consists of seven checks written by Mrs. Coffman totaling $285, to the Temescal Canyon High School. Petitioners’ youngest daughter was a senior at the high school. In 1995, the parents and school authorities decided to put on a graduation night party in the form of an amusement park. They secured the services of an individual who worked for the Disney company, who assisted the various committees in designing items for the party. Many parents and neighbors contributed to this function. The students who attended this function had to pay an admission fee, but petitioners’ substantiation does not include any payment for admission. Basically, petitioners and other parents were spending money to fund a graduation party for the seniors. Their purpose of using the amusement park theme to prevent “partying and drinking” by the graduates is commendable, but it does notPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011