Marvin B. Hubbard - Page 11

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          contemporaneous written acknowledgment from the donee.  Sec.                
          1.170A-13(f)(1), Income Tax Regs.  This written acknowledgment              
          must state the amount of cash or description of property the                
          taxpayer donated and a statement confirming that no consideration           
          was given to the taxpayer.  Sec. 1.170A-13(f)(2), Income Tax                
          Regs.                                                                       
               With respect to the $10,307 claimed for 2000, petitioner               
          listed on the return $6,239 as gifts by cash or check, $3,200 as            
          gifts other than by cash or check, and $870 as a carryover from             
          the prior year.  Petitioner offered into evidence a letter from             
          his church, St. John Baptist, acknowledging contributions of                
          $6,239 for the year 2000.  The letter also confirmed that no                
          goods or services were given to petitioner in exchange for the              
          contributions.  As to the gifts other than by cash or check,                
          petitioner offered into evidence a receipt from “AMVETS”                    
          acknowledging receipt of several items of property.7  Petitioner            
          testified that the representative of the donee, AMVETS, who                 
          received the donation listed the value of the property on the               
          receipt; however, petitioner did not know the basis upon which              
          the representative arrived at the value recorded on the receipt.            
          Although petitioner claimed that much of the property was                   


               7    The receipt listed the following:  Five boxes and five            
          bags of clothing, furniture valued at $2,325, four chairs valued            
          at $275, three tables valued at $825, and one mattress valued at            
          $250.                                                                       





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