Aziz A. Tokh and Susan K. Tokh - Page 12




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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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