Roger F. and Carolyn R. Ellis - Page 10




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          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:                                                       






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