Lawrence K. Mudd - Page 12

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          such deductions must be substantiated with reliable written                 
          records reflecting the name of the donee, the date of the                   
          contribution, and either the amount of any cash contribution or a           
          description of any property contributed.  Sec. 1.170A-13(a) and             
          (b), Income Tax Regs.  Deductions for contributions of $250 or              
          more are disallowed in the absence of a contemporaneous written             
          acknowledgment of the contribution by the donee.  Sec. 170(f)(8);           
          sec. 1.170A-13(f), Income Tax Regs.                                         
               Petitioner first argues that he is entitled to deduct                  
          $3,685.64 for contributions of property made to a religious                 
          children’s home.  Petitioner purchased a number of items which he           
          then gave directly to the home.  As substantiation for these                
          contributions, petitioner provided a list with the various items            
          along with the prices that he paid for them.  No individual item            
          cost more than $89.95.  Petitioner also provided a letter from              
          the charity acknowledging the receipt of “new gym shoes,                    
          sweaters, boots, and food supplies”.  The items on petitioner’s             
          list, primarily consisting of children’s athletic shoes,                    
          correspond to this description.                                             
               At trial, respondent questioned petitioner concerning his              
          lack of receipts for the individual items donated to the                    
          children’s home, but he did not directly challenge the                      
          authenticity or accuracy of petitioner’s list of items or the               
          letter from the charity.  We conclude that the list provided by             






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