Betty Kendrix - Page 12

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               B.  Regulations                                                        
               Pursuant to section 1.170A-13(a)(1), Income Tax Regs., cash            
          contributions must be substantiated by either a canceled check, a           
          receipt from the donee showing the donee’s name and the date and            
          amount of the contribution, or “other reliable written records”             
          showing the donee’s name and the date and amount of the                     
          contribution.  Section 1.170A-13(a)(2), Income Tax Regs.,                   
          provides rules governing the reliability of records.                        
               Pursuant to section 1.170A-13(b)(1), Income Tax Regs.,                 
          noncash contributions must be substantiated, at a minimum, by a             
          receipt from the donee organization showing the name of the                 
          donee, the date and location of the contribution, and a                     
          “description of the property in detail reasonably sufficient                
          under the circumstances.”  Where it is “impractical” to obtain a            
          receipt, taxpayers must maintain “reliable written records” of              
          their noncash contributions.  See id.  Section 1.170A-13(b)(2),             
          Income Tax Regs., provides rules governing the reliability and              
          content of such records, and paragraph (b)(3) provides                      
          information retention and reporting requirements for claimed                
          noncash contributions in excess of $500, which incorporate the              
          rules of paragraph (b)(2)(ii) regarding the content of records.             
               Pursuant to section 1.170A-13(f)(1), Income Tax Regs.,                 
          “[s]eparate contributions of less than $250 are not subject to *            
          * * section 170(f)(8), regardless of whether the sum of the                 






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