Curtis Muhammad - Page 5

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               Section 6001 and section 1.6001-1(a), Income Tax Regs.,                
          require that any person subject to tax or any person required to            
          file a return of information with respect to income, shall keep             
          such permanent books of account or records, as are sufficient to            
          establish the amount of gross income, deductions, credits, or               
          other matter required to be shown by such person in any return of           
          such tax or information.  Deductions are strictly a matter of               
          legislative grace, and the taxpayer bears the burden of proving             
          entitlement to the claimed deduction.  Rule 142(a); INDOPCO, Inc.           
          v. Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v.            
          Helvering, 292 U.S. 435, 440 (1934).                                        
          A.  Charitable Contribution Deductions Claimed on Schedule A                
               Respondent disallowed a deduction of $6,500 that petitioner            
          claimed as charitable contributions.  Respondent argues that                
          petitioner failed to retain adequate records and that the                   
          documents provided by petitioner to support cash contributions              
          should be disregarded because they do not constitute credible               
          evidence.                                                                   
               Section 170(a) allows as a deduction any charitable                    
          contribution the payment of which is made within the taxable                
          year.  Deductions for charitable contributions are allowable only           
          if verified under regulations prescribed by the Secretary.  Sec.            
          170(a)(1).  In general, the regulations require a taxpayer to               
          maintain for each contribution one of the following:  (1) A                 






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