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prepared, of items allegedly contributed on December 31, with a
value of $850,2 but no receipt for this contribution was produced.
The dates on the receipts for January 14 and September 30
appear to have been altered, and we are not satisfied that those
contributions were in fact made during 2002. The list of items
with respect to the purported December 31 contribution does not
support the section 170 deduction because it was prepared
exclusively by petitioners and is therefore not a
“contemporaneous written acknowledgment of the contribution by
the donee organization”.
The remaining five receipts are supported by detailed lists
of items that petitioners allegedly contributed, but the values
listed for the individual items do not add up to the total amount
claimed for each contribution. Additionally, the list of items
purportedly contributed on June 28 includes a situp table and
weights that were also listed in the receipt prepared for the
purported January 14 charitable contribution. And as noted, we
are not satisfied that these items in fact were contributed to
charity in 2002.
2We note that the sums listed on the various receipts
petitioners produced plus the amount on the list of items they
allegedly contributed on Dec. 31 is less than the amount claimed
for noncash contributions on their 2002 tax return. Moreover,
the values claimed for the individual contributed items listed in
the receipts do not total the claimed sum.
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