Norman John Haas III and Susan Renee Haas - Page 7

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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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