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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 the
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