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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 not
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