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Discussion
Deductions are strictly a matter of legislative grace, and
taxpayers must satisfy the specific requirements for any
deduction claimed. See INDOPCO, Inc. v. Commissioner, 503 U.S.
79, 84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435,
440 (1934). Taxpayers are required to maintain records
sufficient to substantiate their claimed deductions. See sec.
6001; sec. 1.6001-1(a), Income Tax Regs.
Section 170(a) allows a deduction for charitable
contributions paid during the taxable year subject to certain
limitations. Deductions for charitable contributions are
allowable only to the extent verified under Treasury regulations.
See sec. 170(a)(1). The applicable regulations require a
taxpayer to maintain for each contribution of money a canceled
check, a receipt from the donee organization showing the date and
amount of the contribution, or other reliable written records
showing the name of the donee and the date and amount of the
contribution. See sec. 1.170A-13(a)(1), Income Tax Regs.
Petitioners have not maintained any of the records required
to substantiate their charitable contributions.
The only evidence of petitioners' contributions consists of
the single sheet of paper containing petitioners' estimates. The
notations on the sheet of paper contain no dates and for the most
part list small amounts. Two large amounts are listed as
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Last modified: May 25, 2011