Regina Missouri - Page 4

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          Petitioner has no receipts or other substantiation to support a             
          charitable contribution deduction for any amount greater than               
          that allowed by respondent.  Petitioner maintained no log or                
          diary with respect to the transportation expenses and has no                
          receipts or other records with respect to the disallowed                    
          miscellaneous deduction.3                                                   
                                     Discussion                                       
          1. Charitable Contribution Deduction.                                       
               Section 170(a) allows a deduction for charitable                       
          contributions “if verified under regulations prescribed by the              
          Secretary.”  Under the regulations, a taxpayer must maintain for            
          each contribution either a cancelled check, a receipt, or other             
          reliable records from the charitable organization.  Sec. 1.170A-            
          13(a)(1), Income Tax Regs.  Petitioner has no such records                  
          substantiating charitable gifts in an amount larger than that               
          allowed by respondent.  We sustain respondent’s determination               
          with respect to this issue.                                                 
          2. Miscellaneous Deduction.                                                 
               Petitioner claimed a deduction for clothing and related                
          expenses and for the use of her automobile.  Section 162(a)                 
          allows deductions for “ordinary and necessary expenses paid * * *           
          in carrying on any trade or business”.  Petitioner is in the                


          3   Petitioner does not satisfy the requirements of sec. 7491(a).           





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