Earl G. Higbee and Lesley A. Higbee - Page 10




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          evidence of a casualty loss, the burden of proof as to this issue           
          is not placed on respondent.  Further, for similar reasons                  
          regarding our discussion of petitioners’ evidence for purposes of           
          section 7491, we conclude that petitioners have not met their               
          burden of proof.  See Rule 142(a).  Consequently, we reject                 
          petitioners’ claimed casualty loss deduction.                               
               B.  Charitable Contributions                                           
               Section 170(a)(1) provides that a taxpayer may deduct “any             
          charitable contribution * * * payment of which is made within the           
          taxable year.  A charitable contribution shall be allowable as a            
          deduction only if verified under regulations prescribed by the              
          Secretary.”  Pursuant to the Treasury regulations, contributions            
          of money are required to be substantiated by canceled checks,               
          receipts from the donee organizations showing the date and amount           
          of the contributions, or other reliable written records showing             
          the name of the donee, date, and amount of the contributions.               
          See sec. 1.170A-13(a)(1), Income Tax Regs.  Similarly,                      
          contributions of property other than money must be substantiated,           
          at a minimum, by a receipt from the donee showing the name and              
          address of the donee, the date and location of the contribution,            
          and a description of the property in detail reasonably sufficient           
          under the circumstances.  See sec. 1.170A-13(b)(1), Income Tax              
          Regs.  Where it is unrealistic to obtain a receipt, taxpayers               
          must maintain reliable written records of their contributions.              






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