Marcus V. and Polly A. Booker - Page 9

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          must state the amount of cash or description of property the                
          taxpayer donated and a statement confirming that no consideration           
          was given to the taxpayer.  Sec. 1.170A-13(f)(2), Income Tax                
          Regs.  The taxpayer is required to include in the records a “good           
          faith estimate” as to the value of goods or property contributed            
          in kind.  Sec. 170(f)(8)(B)(iii).                                           
               Petitioners did not establish at trial that they were                  
          entitled to any deduction for charitable contributions.  They               
          presented as evidence receipts that were furnished blank by                 
          charitable organizations and admittedly filled in by petitioners.           
          This evidence purports to establish that, during 1999,                      
          petitioners donated, among other things, at least 71 bags of                
          clothing, 4 humidifiers, 2 dehumidifiers, 4 vacuum cleaners, 6              
          chairs, and 25 wall fixtures.  The values claimed on the returns            
          are, in the Court’s view, inflated and do not amount to “good               
          faith estimates” of the value of the donated items, nor do they             
          add up to the $9,250 petitioners claimed as donations other than            
          by cash or check.  Petitioners offered little explanation as to             
          how they arrived at the fair market value of the items donated,             
          and no explanation as to how the final amount of $9,250, claimed            
          on their 1999 return, was calculated.  The Court is not satisfied           
          that petitioners made any donations; therefore, the deduction of            
          $9,250 petitioners claimed as charitable contributions other than           
          cash for 1999 is disallowed.                                                

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