Samie M. and Nora L. Finch - Page 14

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          (b), Income Tax Regs.  Deductions for contributions of $250 or              
          more are disallowed in the absence of a contemporaneous written             
          acknowledgment of the contribution by the donee.  Sec. 170(f)(8);           
          sec. 1.170A-13(f), Income Tax Regs.                                         
               Petitioners provided a typed receipt, signed by Bishop                 
          Henderson Wheeler, acknowledging that petitioners contributed               
          $3,359.87 to the First Church of God in Christ.  Petitioners                
          testified that a total amount of $3,359.87 was contributed by               
          them during the taxable year 2002 at Sunday worship services.  In           
          view of the fact that petitioners attended services regularly and           
          that we believe the receipt is credible, we find that the receipt           
          is sufficient substantiation of petitioners’ charitable                     
          contribution of $3,359.87.  However, petitioners have not                   
          testified as to or substantiated charitable contributions above             
          that amount.  Thus, we conclude that petitioners are entitled to            
          a charitable contribution deduction of $3,3606 for the taxable              
          year 2002.                                                                  
          3.   Medical and Dental Expenses                                            
               As previously stated, on their Schedule A for taxable year             
          2002, petitioners claimed a deduction for medical and dental                
          expenses incurred of $219 above the 7.5-percent floor.                      
          Respondent disallowed the deduction in full.  Respondent                    
          determined that petitioners did not prove that the expenses were            

          6This amount is rounded to the nearest dollar.                              




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