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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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