Stanley Joseph Jennings - Page 7




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          He testified that he sometimes contributed cash anonymously so              
          that a recipient could not identify him as the donor.                       
               Petitioner points out that Schedule A refers to charitable             
          gifts by “cash or check” and contends that this means that he may           
          deduct cash contributions in the amounts he claims.  We disagree.           
          A taxpayer with no canceled checks or receipts must verify                  
          charitable contributions with other reliable written records                
          showing the name of the donee, the date, and the amount of the              
          contribution.  See sec. 1.170A-13(a)(1)(iii), Income Tax Regs.              
          Factors showing whether a document (other than check or receipt)            
          is adequate to substantiate a charitable gift include the                   
          contemporaneous nature of the writing, the regularity of the                
          recordkeeping, and, for small contributions, the existence of any           
          written document or other evidence from the donee organization              
          which shows that it received the gift even if it is not a                   
          receipt; e.g., a button, emblem, or other token regularly given             
          by the organization to a donor.  See sec. 1.170A-13(a)(2)(i),               
          Income Tax Regs.                                                            
               Petitioner contends that he may use the 3" by 3" paper and             
          his account register to verify his charitable contributions.                
          There is no evidence showing when petitioner prepared the 3" by             
          3" paper.3  Petitioner contends that he wrote the information on            


               3  On brief, petitioner contends that he prepared the 3" by            
          3" paper after he spoke to Bunten.  There is no evidence that               
          petitioner spoke to her in 1989.                                            





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