Roger F. and Carolyn R. Ellis - Page 11




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               (i) A canceled check.                                                  
               (ii) A receipt from the donee charitable organization                  
               showing the name of the donee, the date of the                         
               contribution, and the amount of the contribution.  A                   
               letter or other communication from the donee charitable                
               organization acknowledging receipt of a contribution                   
               and showing the date and amount of the contribution                    
               constitutes a receipt * * *.                                           
               (iii) In the absence of a canceled check or receipt                    
               from the donee charitable organization, other reliable                 
               written records showing the name of the donee, the date                
               of the contribution, and the amount of the                             
               contribution.                                                          
          If the donation is a small amount, any written or other evidence            
          from the donee charitable organization acknowledging receipt is             
          generally sufficient.  The reliability of the records is                    
          determined on the basis of all relevant facts and circumstances.            
          See sec. 1.170A-13(a)(2)(i)(C), Income Tax Regs.                            
               At trial, petitioners did not indicate how much of the                 
          claimed deduction for each year consisted of cash donations and             
          how much consisted of donations of personal property.  Instead,             
          in addition to petitioner’s generalized testimony regarding their           
          contributions practices, they produced as substantiation for the            
          deductions:  (1) Computer-generated summaries; (2) carbon copies            
          of checks written to various organizations, including, among                
          others, the Church and the Baptist Health Association; (3)                  
          receipts for donations to various organizations, including the              










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