- 11 - 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 byPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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