- 3 - The first issue for decision is whether petitioners are entitled to disallowed deductions for charitable contributions. Petitioners claimed charitable contribution deductions of $9,850, $14,400, and $15,300 in 1995, 1996, and 1997, respectively. Respondent allowed a deduction of only $250 in each of 1995 and 1996, and $450 in 1997, because petitioners failed to establish that any more than these amounts met the requirements of section 170. Respondent allowed petitioners the standard deduction in 1995 and 1996 because their remaining itemized deductions were less than the standard deduction in each year. Section 170(a) allows a deduction for charitable contributions made during the taxable year to certain listed types of organizations, if the deductions are verified under regulations prescribed by the Secretary. Sec. 170(a)(1). A deduction for charitable contributions generally is not allowed in the absence of written records. Sec. 1.170A-13, Income Tax Regs; see also sec. 6001; sec. 1.6001-1(a), (e), Income Tax Regs. Specific requirements, which vary according to the type and amount of the contributions, do not need to be set out in detail here. Petitioners provided no reliable written records to substantiate the charitable contributions, and we do not find credible petitioner’s testimony that he donated these large sums in cash to a single organization, Alcoholics Anonymous. In thePage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011