- 15 - 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,Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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