Brandt N. Castleton - Page 15

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         charitable contributions in accordance with section 170 and the              
         above-cited regulations.  See sec. 6001; Gomez v. Commissioner,              
         T.C. Memo. 1999-94; Brown v. Commissioner, T.C. Memo. 1996-43.               
         Petitioner did not do so.                                                    
              For taxable years 1998 and 2000, petitioner provided                    
         conflicting testimony and documents regarding the identity of the            
         donee organizations and whether his contributions consisted of               
         cash or property or both.  Although the substantiation                       
         requirements for cash and noncash contributions differ, it is not            
         necessary for us to parse the different requirements because                 
         petitioner provided no written substantiation of any kind                    
         regarding his 1998 and 2000 contributions.  Consequently, we                 
         sustain respondent’s determination with regard to petitioner’s               
         claimed 1998 and 2000 charitable contribution deductions.                    
              For taxable year 1999, petitioner again offered conflicting             
         testimony and documents regarding the nature of his charitable               
         contributions.  Petitioner’s only documentation of his 1999                  
         contributions is a receipt, allegedly from RRS, that indicates               
         petitioner made a $15,320 contribution to the organization during            
         1999.  The receipt is not sufficient substantiation of                       
         petitioner’s 1999 charitable contributions for several reasons.              
              First, petitioner did not prove that RRS was a qualifying               
         organization under section 170.  Section 170(c)(2) defines                   
         charitable contribution, in pertinent part, to mean a                        
         contribution or gift to or for the use of a corporation, trust,              




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