Warren McKinnley Dowdy - Page 6

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          mostly used clothing, to either the Salvation Army or the Red               
          Cross.                                                                      
               In general, a taxpayer is allowed to deduct any                        
          contributions or gifts made to qualifying organizations for their           
          use.  See sec. 170(a).  Section 1.170A-13(a)(1), Income Tax                 
          Regs., requires that charitable contribution deductions, whether            
          made by cash or otherwise, be substantiated by at least one of              
          the following:                                                              
                    (i) A canceled check.                                             
                    (ii) A receipt from the donee charitable                          
               organization showing the name of the donee, the                        
               date of the contribution, and the amount of the                        
               contribution.  A letter or other communication from the                
               donee charitable organization acknowledging receipt of a               
               contribution and showing the date and amount of the                    
               contribution constitutes a receipt * * *.                              
                    (iii) In the absence of a canceled check or                       
               receipt from the donee charitable organization, other                  
               reliable written records showing the name of the donee,                
               the date of contribution, and the amount of the                        
               contribution.                                                          
               If the donation is a small amount, any written or other                
          evidence from the donee charitable organization acknowledging               
          receipt is generally sufficient.  The reliability of the records            
          is determined on the basis of all relevant facts and                        
          circumstances.  See sec. 1.170A-13(a)(2)(C), Income Tax Regs.               
               In this case none of the contributions that petitioner                 
          claims to have made are supported by any of the types of                    
          substantiating documents described above.  That being so,                   






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