Lawrence K. and Ruth L. Harrell - Page 6

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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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