Brandt N. Castleton - Page 16

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         or community chest, fund or foundation that is organized and                 
         operated exclusively for religious, charitable, scientific,                  
         literary, or educational purposes.  The parties stipulated that              
         RRS had not applied for or received an exemption from taxation as            
         an organization described in section 501(c)(3) during or before              
         1998, 1999, and 2000.  Moreover, petitioner did not prove that               
         RRS was an organization of the type described in section                     
         170(c)(2).                                                                   
              Second, even if petitioner had proved that RRS was a                    
         qualifying organization under section 170(c)(2), the RRS receipt             
         did not contain the necessary information to adequately                      
         substantiate petitioner’s alleged 1999 contributions.  The                   
         receipt purported to substantiate a contribution and did not                 
         indicate that any noncash contribution had been made.  If                    
         petitioner had made a noncash contribution as he testified, the              
         receipt should have described the location of the contributions              
         and the property contributed.  The receipt also should have                  
         stated whether the donee provided goods or services as a quid pro            
         quo.  Sec. 170(f)(8)(B)(ii).  The receipt did not provide any of             
         the information necessary to substantiate the contribution that              
         petitioner testified he made.                                                
              Third, because petitioner testified that he made noncash                
         contributions having a value in excess of $5,000, petitioner was             
         required to obtain a qualified appraisal.  Petitioner did not                






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