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OPINION
A. Charitable Deductions
Petitioner contends that he may deduct charitable
contributions in the amounts of $36,960.30 for 1994, $25,028.40
for 1995, and $32,522.32 for 1996. Respondent contends that
petitioner may not deduct any of those amounts. We agree with
respondent primarily because petitioner has not substantiated the
contributions as required by section 170(a)(1) (taxpayer must
verify claimed contribution under regulations prescribed by the
Secretary) and section 1.170A-13(a)(1), Income Tax Regs., and
secondarily because he has not shown that he made contributions
to organizations described in section 170(c).
1. Cash Contributions During the Years in Issue
Petitioner contends that he may deduct charitable gifts of
cash without any documentary proof. We disagree. Petitioner
must substantiate the date, amount, and donee of charitable
contributions of money with: (a) A canceled check; (b) a receipt
from the donee organization; or (c) in the absence of a canceled
check or receipt, other reliable written records. See sec.
1.170A-13(a)(1), Income Tax Regs.; see also Coffman v.
Commissioner, T.C. Memo. 2000-7; Thorpe v. Commissioner, T.C.
Memo. 1998-123.
Petitioner made no contributions by check and had no
receipts for any cash contributions during the years in issue.
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Last modified: May 25, 2011