- 14 - 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.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011