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charitable, scientific, literary, or educational purposes. Sec.
170(c)(2)(B).
If a taxpayer makes a charitable contribution in cash or by
check, the taxpayer shall maintain for each contribution either a
canceled check, a receipt or letter from the donee charitable
organization, or other reliable written records showing the name
of the donee and the date and amount of the contribution.
Cavalaris v. Commissioner, T.C. Memo. 1996-308; sec. 1.170A-
13(a)(1), Income Tax Regs. If the contribution is made in
property other than money, the taxpayer must also maintain a
receipt or letter from the donee showing the name of the donee,
the date and location of the contribution, and a description of
the property. Sec. 1.170A-13(b)(1), Income Tax Regs. In the
case where a receipt would be impractical to obtain, the taxpayer
shall maintain reliable written records with respect to each item
of donated property. Id. A deduction for a contribution of $250
or more will not be allowed unless the taxpayer substantiates the
contribution with a contemporaneous written acknowledgment from
the donee organization. Sec. 1.170A-13(f)(1), Income Tax Regs.
Petitioners did not provide any documentary evidence that
reflects their claimed charitable contributions. Mrs. Whitehurst
provided conflicting testimony at trial concerning receipts for
the claimed charitable contributions; on the one hand, she
alleged that she was in possession of receipts, but she also
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