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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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