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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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