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Petitioner testified that a fundamental principle of the
Moslem faith is to make charitable contributions each year equal
to 2.5 percent of an individual’s possessions. Petitioners argue
that the amounts claimed are roughly equal to 2.5 percent of
their possessions.
Petitioners have failed to meet the substantiation
requirements of section 1.170A-13(a)(1), Income Tax Regs.,
because they did not produce any records that would identify the
recipient or prove that the contributions were actually made.
Therefore, petitioners are not entitled to deductions for
monetary contributions in excess of the amounts already allowed
by respondent. Neither are petitioners entitled to deduct their
travel expenses of commuting between their home and the ICC or
mosques. Travel expenses related to attending religious
functions are personal in nature and are not deductible as
charitable contributions. See Churukian v. Commissioner, T.C.
Memo. 1980-205.
Where a charitable contribution is made in property other
than money, a deduction is allowed for the fair market value of
the property at the time of contribution. See sec. 1.170A-
1(c)(1), Income Tax Regs. Petitioners attached “receipts” to
their Federal income tax returns that included descriptions and
estimated fair market values for over 300 items donated to the
Cancer Federation and the Military Order of the Purple Heart.
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