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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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Last modified: May 25, 2011