James R. and Janet M. Landrum - Page 20

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          concerning their need for funds for retirement savings and other            
          purposes, and their complete failure of substantiation by check             
          or receipt or corroborating testimony, we decline to believe                
          petitioners’ self-serving testimony as to their cash                        
          contributions.  We hold that petitioners are not entitled to                
          deductions for cash contributions beyond the amounts allowed by             
               For charitable contributions of property other than money,             
          taxpayers generally must maintain for each contribution a receipt           
          from the donee showing the following information:  (1) The name             
          of the donee; (2) the date and location of the contribution; and            
          (3) a description of the property in detail reasonably sufficient           
          under the circumstances.  Sec. 1.170A-13(b)(1), Income Tax Regs.            
          The amount of the contribution is the fair market value of the              
          property at the time of the contribution.  Sec. 1.170A-1(c)(1),             
          Income Tax Regs.                                                            
               Petitioners’ contributions of property other than money                
          consisted of used clothing and household appliances.  To                    
          substantiate their values, petitioners offered documents                    
          consisting of preprinted forms issued by charitable organizations           
          that petitioners filled in with the type and number of items                
          allegedly donated and the estimated value of the donation.                  
          Petitioners testified that they determined the values by                    

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