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the 3" by 3" paper after he telephoned the church. However,
there is no evidence about when petitioner telephoned the church
or to whom he spoke. Thus, petitioner has not shown that his
preparation of the 3" by 3" paper was contemporaneous or part of
a regular recordkeeping procedure. See sec. 1.170A-
13(a)(2)(i)(A) and (B), Income Tax Regs. The 3" by 3" paper does
not establish that petitioner made a charitable contribution of
$6,074.
Petitioner contends that his account register establishes
that he made charitable contributions of $7,500 in 1995 and
$7,810 in 1996. We disagree. Section 1.170A-13(a)(1)(iii),
Income Tax Regs., requires that the name of the donee be shown on
the reliable written record. Petitioner did not list the names
of the donees for withdrawals of $7,500 for 1995 and $7,810 for
1996. He also testified that he contributed unspecified amounts
of cash to what he said was the Lou Gehrig’s Disease Association
through the wife of his former pastor in Chicago because his
former pastor had contracted Lou Gehrig’s disease. He also
testified that he contributed an unspecified amount of cash to
his neighbor who gave it to the American Cancer Society.4
4 Petitioner testified that he contributed to the American
Cancer Society which is listed in IRS Publication 78. However,
petitioner has no record showing that he made a contribution to
the American Cancer Society. He did not testify when or how much
he gave to the American Cancer Society.
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