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charitable contributions of $11,650 for the year 1999, consisting
of $2,400 by cash or check and $9,250 by other than cash or
check, and $13,405 for the year 2000, consisting of contributions
of $2,400 by cash or check and $11,005 by other than cash or
check. Respondent disallowed the deductions for both years for
lack of substantiation.
Section 170 allows a deduction for charitable contributions
during the taxable year if verified as provided in the
regulations. Sec. 170(a)(1). The term “charitable contribution”
includes a contribution or gift to a corporation, trust, or
community chest, fund, or foundation, with certain provisos.
Sec. 170(c). For example, the recipient organization must have
been “created or organized in the United States or in any
possession thereof, or under the law of the United States, any
State, the District of Columbia, or any possession of the United
States”. Sec. 170(c)(2)(A). Furthermore, no part of the net
earnings of a qualified organization may inure to the benefit of
any private shareholder or individual. Sec. 170(c)(2)(C).
The charitable contributions deduction is subject to certain
substantiation requirements. Sec. 170(f)(8). No deduction is
allowed for any contribution of $250 or more unless the taxpayer
substantiates the contribution by a contemporaneous written
acknowledgment of the contribution by the qualified donee
organization. Sec. 170(f)(8)(A). This written acknowledgment
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