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B. Charitable Contributions
Petitioners claimed a total deduction of $7,375 in
charitable contributions for the year at issue. Section 170(a)
provides a "deduction [for] any charitable contribution" made to
a qualified donee under section 170(c). Section 170(f) provides
record keeping requirements for certain charitable contributions.
A deduction for any charitable contribution of $250 or more will
be disallowed "unless the taxpayer substantiates the contribution
by a contemporaneous written acknowledgment" prepared by the
donee. Sec. 170(f)(8)(A). The written acknowledgment must
include (1) the amount of cash contributed, (2) whether the donee
organization provided any goods or services in consideration of
the donation, and (3) a description and good faith estimate of
the value of those goods or services. Sec. 170(f)(8)(B). A
written acknowledgment is contemporaneous if the taxpayer obtains
the statement on or before the earlier of (1) the date on which
the taxpayer files a return for the taxable year in which the
contribution was made, or (2) the due date (including extensions)
for filing the return. Sec. 170(f)(8)(C).
Of the total $7,375 deducted for charitable contributions,
petitioners substantiated $4,775 with contemporaneous written
acknowledgments prepared by the donees.6 Of the remaining
6 The written acknowledgments are from the Vehicle
Donation Processing Center, Inc., and Friends of the Filipinos.
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Last modified: May 25, 2011