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A canceled check; (2) a receipt or letter from the donee
charitable organization showing the name of the donee, and the
date and the amount of the contribution; or (3) other reliable
records showing the name of the donee, and the date and the
amount of the contribution. Id. Petitioners’ church donations
do not meet the requirements of section 1.170A-13(a)(1), Income
Tax Regs. See Blair v. Commissioner, T.C. Memo. 1988-581.
Where a charitable contribution is made of property other
than money, section 170 allows a deduction of the fair market
value of the property at the time of contribution. See sec.
1.170A-1(c)(1), Income Tax Regs. Petitioners bear the burden of
proving both the fact that the contribution was made and the fair
market value of the contributed property. See Rule 142(a); Zmuda
v. Commissioner, 79 T.C. 714, 726 (1982), affd. 731 F.2d 1417
(9th Cir. 1984).
During the examination of petitioners’ return, respondent
asked them for an itemized list of the values of the items they
donated. Petitioner testified that “And what I did at the time
was I divided it by the number of gifts that I had given to these
charities.” He also testified that he was told that “certain
receipts I should only claim $200 because that’s the total value
of those gifts, and some gifts I could have claimed up to $499”,
but that he did not know it at the time. Petitioner testified
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