Marcus V. and Polly A. Booker - Page 10

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               Petitioners also claimed, on their 1999 return, a deduction            
          of $2,400 for cash donations under section 170.  Petitioners                
          claimed this consisted of cash donations made to various                    
          churches, Mrs. Booker’s mother, and street beggars.  When                   
          questioned about written substantiation, Mr. Booker responded:              
          “I just made a rough estimate.”  Any money petitioners gave to              
          street beggars, sometimes referred to as “pan handlers”, or to              
          relatives for their support is not deductible under section 170             
          as charitable contributions.  Sec. 170(c).  Petitioners did not             
          substantiate the amount of their other contributions, nor did               
          they establish that the organizations they contributed to were              
          qualified organizations.  The deduction of $2,400 in cash                   
          contributions claimed by petitioners is, therefore, disallowed.             
               With respect to the year 2000, petitioners also presented              
          filled-in receipts from various charitable organizations listing            
          donations received.  At trial, however, Mrs. Booker testified               
          that the lists did not represent items actually donated in 2000,            
          but was “Not 2000.  Just--that was a list--he [Mr. Booker] has              
          the forms for the year 2000.  I just made that list up * * *.  I            
          just made a list of items in which we have replaced over a period           
          of time.”  Mrs. Booker then testified she was sure she had                  
          donated a copier and computer during 2000 but offered no proof of           
          such donations.  In addition, petitioners offered no evidence as            
          to the cash donations claimed on their 2000 return.  Due to the             

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