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provides factors to consider in making this determination,
including: (1) Whether the writing that evidences the
contribution was written contemporaneously and (2) whether the
taxpayer keeps regular records of the contributions.
Petitioner testified that because he had made all of his
charitable contributions in cash, he had no canceled checks.
Petitioner failed to provide any receipts from the church. The
only records petitioner provided were the lists, which he created
with the help of his tax preparer, showing weekly payments to the
church. These lists were not prepared contemporaneously with the
alleged contributions.
We find that petitioner failed to provide reliable evidence
of his purported contributions and failed to meet his burden of
proof. We hold that respondent’s determinations disallowing
petitioner’s claimed charitable contribution deductions are
sustained.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011