Florence C. Blankson - Page 15




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          literary, educational, or other specifically enumerated purposes.           
          Sec. 170(c)(2)(B).  The contribution or gift is deductible only             
          “if it is to be used within the United States or any of its                 
          possessions exclusively” for those purposes.  Sec. 170(c)(2).               
          Further, no part of the net earnings of a qualified organization            
          may inure to the benefit of any private shareholder or                      
          individual.  Sec. 170(c)(2)(C).                                             
               The charitable contributions deduction is subject to certain           
          substantiation requirements.  Sec. 170(f)(8).  No deduction is              
          allowed for any contribution of $250 or more unless the taxpayer            
          substantiates the contribution by a contemporaneous written                 
          acknowledgment of the contribution by the qualified donee                   
          organization.  Sec. 170(f)(8)(A).  The standards for record                 
          keeping and return requirements for deductions for charitable               
          contributions are set forth in section 1.170A-13, Income Tax                
          Regs.                                                                       
               Petitioner did not establish at trial that she is entitled             
          to charitable contribution deductions in excess of the amounts              
          allowed by respondent.  Donations she made to individuals do not            
          qualify for the deduction due to the applicable restrictions on             
          qualified donee organizations.  Sec. 170(c).  Respondent allowed            
          those contributions that were properly substantiated, and the               
          Court declines to allow any additional amounts.  Respondent is              
          sustained on this issue.                                                    





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