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The “receipts” were contemporaneously created by petitioners on
forms provided by the charities without specification of the
items donated at the time that the donations were made.
Respondent argues that these receipts are inadequate because they
do not show the original cost, age, or condition of the donated
items. Petitioner was unable to cure any defects in the
documentation by his testimony.
Petitioners’ claimed deductions of $680 in 1996 and $1,394
in 1997 for the donated items. However, the lists of items for
1997 total only $891. We conclude that the self-generated
“receipts” are unreliable. Petitioners are not entitled to
deductions for noncash charitable contributions in excess of the
amounts already allowed by respondent.
Rental Property Expenses
Petitioners claimed deductions in excess of the amount
allowed by respondent for expenses attributable to the
condominium that they held for rental purposes in 1996.
Respondent conceded that petitioners are entitled to deductions
equal to $4,411 for rental property expenses. For the remainder
of the alleged expenses, petitioners either failed to produce
receipts and records to substantiate their claims or petitioners
produced receipts that appear to relate to petitioners’ private
residence rather than to the condominium.
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Last modified: May 25, 2011