- 9 - disallowing all of the deductions claimed on the Schedules C are sustained. B. Charitable Contribution Deductions Petitioners claimed charitable contribution deductions of $8,382 and $10,827, for 1995 and 1996, respectively, on the Schedules A included with their returns for those years. For each year, they indicated that the contributions were made in cash; but at trial, they claimed that some contributions consisted of donations of personal property and some portion of the deductions was attributable to transportation expenses. In general, a taxpayer is allowed to deduct any contributions or gifts made to qualifying organizations for their use. See sec. 170(a). Subject to various exceptions, if property other than money is donated, “the amount of the contribution is the fair market value of the property at the time of the contribution”. Sec. 1.170A-1(c)(1), Income Tax Regs. Fair market value is defined as “the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of relevant facts.” Sec. 1.170A-1(c)(2), Income Tax Regs. Section 1.170A-13(a)(1), Income Tax Regs., requires that charitable contribution deductions be substantiated by at least one of the following:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011