- 30 -
U.S.C. sec. 2710(b)(3)(D). We accordingly sustain respondent's
determination that petitioners failed to report $3,000 in taxable
income arising from the payments in that amount made to them by
the Oneida Tribe in 1999.
Charitable Contributions
Section 170(a) generally allows a deduction for
contributions made to certain designated entities, provided such
contributions are verified under regulations prescribed by the
Secretary. Depending upon the size of the contribution, the
verification requirement is satisfied by reliable written records
or by a written acknowledgment from the recipient entity. See
sec. 170(f)(8); sec. 1.170A-13(a)(1), Income Tax Regs.
Respondent disallowed petitioners' claimed charitable
contribution deductions of $5,899 and $3,969 for 1997 and 2000,
respectively, for failure to substantiate the deductions.
Petitioners claim to have submitted substantiation of their 1997
and 2000 charitable contribution deductions to respondent's field
office in Green Bay, Wisconsin. However, they have not produced
any evidence in support of this claim or provided any written
evidence to verify or substantiate the claimed deductions.21
In the absence of evidence to verify or substantiate
petitioners' claimed charitable contribution deductions, we
21 On the basis of his testimony, Mr. Doxtator appears to
believe that a taxpayer is entitled to a charitable contribution
deduction equal to 10 percent of his income, without regard to
verification or substantiation.
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