Marcus V. and Polly A. Booker - Page 8

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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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