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bowling scoring sheets that reflected most, but not all, of the
claimed deductions for the entry fees for the bowling tournaments
in which Mrs. Whitehurst competed. On the basis of a review of
the evidence in the record, we are satisfied that petitioners are
entitled to deductions for entry fees of $8,700 in 1997, $7,968
in 1998, and $7,415 in 1999.
Issue 3. Schedule A Itemized Deductions
a. Charitable Contributions
Petitioners claimed deductions for charitable contributions
of $2,960 made in cash or by check and $500 made other than in
cash or by check for 1997, $2,570 made in cash or by check and
$500 made other than in cash or by check for 1998, and $2,255
made in cash or by check and $500 made other than in cash or by
check for 1999.
The notice of deficiency disallowed the claimed deductions
for charitable contributions in part as follows: $1,980 for
1997, $1,785 for 1998, and $1,628 for 1999. Respondent
disallowed portions of the claimed charitable contributions
because petitioners did not substantiate the claimed amounts.
Section 170(a)(1) allows as a deduction a charitable
contribution payment of which is made within the taxable year. A
charitable contribution includes a contribution or gift to or for
the use of a corporation, trust, community chest, fund, or
foundation organized and operated exclusively for religious,
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