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Petitioner did not testify when he made those gifts. He has no
records or receipts for these contributions.
He listed as donees the Bradfield Building Fund ($1,000 in
1995), World Challenge ($800 in 1995 and $500 in 1996), Lou
Gehrig’s Disease Association ($800 in 1996), and American Cancer
Association ($700 in 1996) as donees. The register shows the
dates and amounts of the withdrawals, but not the dates and
amounts of contributions.
Petitioner must show that the donees are organizations
described in section 170(c). See sec. 170(a)(1). None of the
organizations petitioner named were listed in IRS Publication 78,
“Cumulative List of Organizations described in Section 170(c) of
the Internal Revenue Code of 1986"5 during the years in issue.
Petitioner did not show that the Bradfield Building Fund, World
5 Publication 78, "Cumulative List of Organizations
described in Section 170(c) of the Internal Revenue Code of
1986", contains a list of organizations with outstanding rulings
or determination letters holding that contributions to these
organizations are deductible. The list is not all-inclusive. If
an organization is not listed but has received a determination
letter from the IRS, contributors are generally permitted to
deduct their donations. However, if an organization has not
received such a letter, contributors are not permitted to deduct
their donations, unless it is an organization described in sec.
170(c)(1); i.e., a State, a possession of the United States, or
any political subdivision of the foregoing, or the United States
or the District of Columbia.
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