John Arthur & Patricia Mulholland Beecroft - Page 4




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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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