Lawrence K. Mudd - Page 13

                                       - 12 -                                         
          petitioner and the written acknowledgment from the donee meet the           
          section 170 substantiation requirements, despite petitioner’s               
          failure to maintain the individual receipts.  Sec. 1.170A-13,               
          Income Tax Regs.                                                            
               Petitioner next argues that he is entitled to deduct two               
          amounts paid in connection with a religious organization’s                  
          housing development project.  First, he made a $50 cash donation            
          to the organization.  Petitioner provided a handwritten receipt             
          from the charity acknowledging receipt of the $50.  We find that            
          this receipt is sufficient substantiation of the contribution.              
          Id.  Second, petitioner argues that he incurred mileage expenses            
          for driving to the housing project and working there.5                      
          Petitioner did not provide substantiation of these expenses,                
          other than his testimony that he drove “approximately 600 miles”-           
          -he did not provide a mileage log or even any corroboration that            
          he participated in the program.  We find that petitioner has not            
          substantiated the mileage expenses.  Sec. 6001; sec. 1.6001-1(a),           
          (e), Income Tax Regs.                                                       
               We conclude that petitioner made deductible charitable                 
          contributions of $3,735.64 during 1996.                                     





          5Sec. 170(i) prescribes the standard mileage rate for                       
          purposes of computing the amount of a sec. 170(a) charitable                
          contribution deduction.                                                     




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

Last modified: May 25, 2011