Braun Michael and Twanda B. Cameron - Page 7

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               Section 170 allows as a deduction any charitable                       
          contribution actually paid during the taxable year.  Sec.                   
          170(a)(1); sec. 1.170A-1(a), Income Tax Regs.  A taxpayer may               
          claim a deduction for a “charitable contribution”, which is                 
          defined as a contribution made “to or for the use of” a qualified           
          organization.  Sec. 170(c); Davis v. United States, 495 U.S. 472,           
          478 (1990).  The regulations provide specific record-keeping                
          requirements.  With respect to each charitable contribution of              
          money in a taxable year beginning after December 31, 1982, a                
          taxpayer is required to maintain one of the following:  (1) A               
          canceled check; (2) a receipt or letter from the donee indicating           
          the name of the donee, the date of the contribution, and the                
          amount of the contribution; or (3) any other reliable written               
          record showing the name of the donee, the date of the                       
          contribution, and the amount of the contribution.  Sec. 1.170A-             
          13(a)(1), Income Tax Regs.                                                  
               To begin with, we note that petitioners claim a deduction              
          for contributions made to Ms. Perry, petitioner’s elderly aunt.             
          Although petitioners generously provided their time and financial           
          resources to Ms. Perry, these contributions were not donations              
          for which section 170 allows a deduction.  Ms. Perry is not a               
          qualified charitable organization, and contributions to her are             

          v. Commissioner, 116 T.C. 438, 444 (2001); Caralan Trust v.                 
          Commissioner, T.C. Memo. 2001-241.                                          

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