A. Wayne and Linda D. Doudney - Page 9

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          helpful in carrying on a trade or business.  Heineman v.                    
          Commissioner, 82 T.C. 538, 543 (1984).                                      
               Under section 164, a taxpayer may deduct State and local               
          real property and income taxes paid or accrued during the taxable           
          year.  A real property tax is one that is imposed upon real                 
          property to benefit the general public welfare.  Sec. 1.164-3(b),           
          Income Tax Regs.  A State or local tax is one that is imposed by            
          a State, by a possession of the United States, by a political               
          subdivision of either, or by the District of Columbia.  Sec.                
          1.164-3(a), Income Tax Regs.                                                
               Section 170 allows a deduction for charitable contributions            
          made to qualifying organizations.  A taxpayer claiming a                    
          charitable deduction of money must maintain a copy of the                   
          donation check, a receipt of the donation by the donee                      
          organization, or some other reliable written evidence of                    
          donation.  Sec. 1.170A-13(a)(1), Income Tax Regs.  Contributions            
          of property require, at a minimum, a receipt by the donee                   
          including the name of the donee, the date and location of the               
          donation, and a reasonable description of the property donated.             
          Sec. 1.170A-13(b).  Where it is unrealistic to obtain a receipt,            
          the taxpayer must maintain reliable written records of his                  
          contributions.  See id.                                                     
               All deductions, however, are a matter of legislative grace,            
          and the taxpayer must clearly demonstrate entitlement to the                






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