- 3 - 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).Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011