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States”. Sec. 170(c)(2)(A). Furthermore, no part of the net
earnings of a qualified organization may inure to the benefit of
any private shareholder or individual. Sec. 170(c)(2)(C).
The charitable contribution deduction is subject to certain
substantiation requirements. Sec. 170(f)(8). No deduction is
allowed for any contribution of $250 or more unless the taxpayer
substantiates the contribution by a contemporaneous written
acknowledgment of the contribution by the qualified donee
organization. Sec. 170(f)(8)(A). This written acknowledgment
must state the amount of cash and a description (but not
necessarily the value) of any property other than cash the
taxpayer donated and whether any consideration was given to the
taxpayer. Sec. 1.170A-13(f)(2), Income Tax Regs.
Petitioners attached to their 2002 Form 1040 a Form 8283,
Noncash Charitable Contributions, listing eight dates on which
they claimed to have made noncash donations to charitable
organizations. At trial, petitioners presented as evidence
receipts that were furnished blank by charitable organizations
and admittedly filled in by petitioners. The receipts, which
total $6,903, purport to show that petitioners made noncash
contributions on seven separate dates during 2002: January 14,
March 15, May 14, June 28, August 16, September 30, and November
21. In addition, petitioners submitted a list, which they
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