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As noted earlier, petitioner conceded the disallowance of the
cash contributions. At trial, petitioner argued he is entitled
to deduct the noncash portion of the contributions.
Although petitioner deducted $413 in noncash charitable
contributions for 1999, he presented at trial copies of three
receipts from two recipient organizations totaling $1,512.99 for
that year. For the 2000 tax year, petitioner presented two
receipts totaling $630. For both years, the receipts described
the items donated as household goods, designer clothing, and
"fine clothing". Except for one receipt, all the amounts shown
as values of the donated items were amounts inserted on the
receipts by petitioner. Petitioner presented no detailed
information regarding the property, any appraisals, cost, or the
manner in which the amounts claimed as deductions were
determined. No explanation was offered at trial as to the cost
or basis of the donated properties.
Section 170(a)(1) allows a deduction for any charitable
contribution to or for the use of an organization described in
section 170(c), payment of which is made during the taxable year.
No question was raised by respondent as to whether the donees in
this case were qualified organizations under section 170(c).
Leaving that question aside, in general, the amount of a
charitable contribution made in property other than money is the
fair market value of the property at the time of the
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