Norman John Haas III and Susan Renee Haas - Page 6

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          shows that the odometer indicated 152,759 miles when the truck              
          was recovered.                                                              
               The parties stipulated a portion of the January-April 2001             
          Edition of the Kelly Blue Book Older Car Guide 1981-1994 Models             
          (Blue Book) that provides a range of values in 2001 for 1991                
          model trucks, including petitioners’ make and model.                        
               The Commissioner’s determinations are presumed correct, and            
          generally taxpayers bear the burden of proving otherwise.  Rule             
          142(a)(1).  Petitioners have neither argued for nor met the                 
          requirements for the application of section 7491(a).  Because               
          section 7491(a) is not here applicable, the burden of proof does            
          not shift to the Commissioner.                                              
          Petitioners’ Charitable Gifts                                               
               Respondent denied petitioners’ deduction for $300 of cash              
          gifts for lack of substantiation.  Petitioner testified that “me            
          and my wife gave $25 in cash at that time to our church.”  He               
          testified that they have no receipts and no letter from the                 
          church.  “I mean you put the money in the basket”, he further               
          explained in his testimony.                                                 
               Taxpayers are required to keep records of charitable                   
          contributions of money.  Section 1.170A-13(a)(1), Income Tax                
          Regs., requires substantiation for charitable contribution                  
          deductions.  A taxpayer must maintain one of the following:  (1)            

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