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3. Charitable Contributions
Section 170 allows a taxpayer to deduct a charitable
contribution "only if verified under regulations prescribed by
the Secretary." Sec. 170(a)(1). The regulations provide
specific record-keeping requirements. With respect to each
charitable contribution of money in a taxable year beginning
after December 31, 1982, a taxpayer is required to maintain one
of the following: (1) A canceled check; (2) a receipt or letter
from the donee indicating the name of the donee, the date of the
contribution, and the amount of the contribution; or (3) any
other reliable written record showing the name of the donee, the
date of the contribution, and the amount of the contribution.
Sec. 1.170A-13(a)(1), Income Tax Regs.
At trial, Mr. Swagler conceded that petitioners could not
substantiate their claimed charitable contributions.
Respondent's disallowance of the entire $1,452 claim for
charitable contributions is sustained.
4. Schedule E Rental Real Estate Expense Deductions
Respondent disallowed $86 of the expenses pertaining to
McVicker and $1,907 of the expenses pertaining to Gettysburg for
lack of substantiation. At trial, petitioners submitted a number
of receipts, cash register tapes, and invoices to substantiate
their claimed deductions. With regard to most of the receipts
and cash register tapes, the Court is unable to determine from
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