- 18 - amounts claimed as contributions on petitioners’ 1996 and 1997 Federal income tax returns. Deductions for charitable contributions are allowable only if verified under regulations prescribed by the Secretary. Sec. 170(a). Section 1.170A-13, Income Tax Regs., in turn, sets forth the types of substantiation necessary to support deductions for charitable contributions. For charitable contributions of money, taxpayers must maintain for each contribution one of the following: (1) A canceled check; (2) a receipt from the donee organization; or (3) other reliable written records. Sec. 1.170A-13(a)(1), Income Tax Regs. Petitioners testified that they regularly made cash and check contributions averaging $50 per week to First Assembly of God in Lawton, Oklahoma. Petitioners, however, could produce no evidence in support of this claim. Petitioners testified that they lost the receipts, and that the church did not have any records dating back to either 1996 or 1997. Petitioners had no canceled checks to substantiate any portion of their alleged contributions. We are not required to accept a taxpayer’s uncorroborated testimony at face value if it is improbable, unreasonable, or questionable. Lovell & Hart, Inc. v. Commissioner, 456 F.2d 145, 148 (6th Cir. 1972), affg. T.C. Memo. 1970-335; Tokarski v. Commissioner, 87 T.C. 74, 77 (1986). In view of their testimonyPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011