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At trial, petitioners presented a list of checks and the
amounts of each check for contributions to their church during
1999. However, no copies of the checks or other receipts to
substantiate the amounts listed were submitted. The list,
although purportedly prepared by the church, was not signed by
either the pastor or any representative of the church. For 1998,
petitioners presented a similar list of their contributions to
the same church but also included check register receipts
totaling $200. No documentation was submitted for church
contributions during 1997. Petitioners presented copies of
several receipts for noncash contributions during 1999 to an
organization, Arc of New Mexico; however, except for three
receipts, the properties donated are not described, nor are any
costs or values shown for such properties. The three receipts
that did list values were in the amounts of $800, $675, and $375.
Two other receipts were submitted for noncash contributions to
Clothes Helping Kids for various household items donated during
1997. These receipts listed values of $400 and $250 for the
household items. Petitioners' tax returns did not include
Internal Revenue Service Form 8283, Noncash Charitable
Contributions, of property other than money, which form is
required for noncash contributions in excess of $600.6
6 Although petitioners claimed less than $500 in noncash
charitable contributions on their returns for each of the years
(continued...)
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