- 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.Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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