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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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Last modified: May 25, 2011