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mortgage or for the alleged payments made with respect thereto.
While we accept petitioner’s testimony that at some point in time
he obtained a second mortgage on his residence, petitioner’s
uncorroborated testimony was insufficient to substantiate the
existence of, or payments on, a second mortgage during 1999. We
sustain respondent’s disallowance of the relevant portion of the
mortgage interest deduction. Sec. 6001; sec. 1.6001-1(a), (e),
Income Tax Regs.
The second deduction in dispute is the deduction for
charitable contributions. The $250 portion of the deduction
disallowed by respondent represents the portion of petitioner’s
deduction that was claimed for noncash contributions. Subject to
various requirements and limitations, charitable contributions
may be deducted under section 170(a). In addition to the general
substantiation requirements noted above, deductions for
charitable contributions are allowed only if certain record-
keeping requirements are met. Sec. 170(a)(1); sec. 1.170A-13,
Income Tax Regs. With respect to noncash contributions,
taxpayers generally must obtain a receipt or other written record
from the donee showing the name of the donee, the date and
location of the contribution, and a description of the property
contributed. Sec. 1.170A-13(b)(1), Income Tax Regs. If
obtaining a receipt is impractical, the taxpayer must nonetheless
keep “reliable written records with respect to each item of
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Last modified: May 25, 2011