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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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Last modified: May 25, 2011