Betty Kendrix - Page 16

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               The 2001 Gospel Temple Baptist Church receipt, like the 2000           
          receipt, fails to state whether the church provided any goods or            
          services in consideration, in whole or in part, for the                     
          contributions listed therein.  Therefore, all of the listed                 
          contributions of $250 or more are nondeductible pursuant to                 
          section 170(f)(8)(B)(ii).  Only the $200 “Revival” contribution,            
          the $100 “Annual Choir Concert” contribution, and the respective            
          April, June, September, and December contributions of $200, $200,           
          $225, and $150 (a total of $1,075) are not subject to section               
          170(f)(8) and are, therefore, deductible.5                                  
               B.  Noncash Contributions                                              
               On brief, petitioner claims to have “documented” noncash               
          contribution deductions of $9,979 for 2000 and $3,329 for 2001,             
          although the total dollar value of the items listed on the                  
          worksheets attached to the 2000 amended Form 8283 is $10,339, not           
          $9,979.  She claims that her “documented contributions be allowed           
          for 2000 and 2001.”                                                         
               In support of her valuations of the donated items, which               
          consist of used clothing and accessories, housewares, linens,               
          books, furniture, audio/video equipment, and home appliances,               
          petitioner attached to her opening brief a printed sheet of                 


               5  Consistent with her position for 2000, petitioner                   
          concedes, on brief, that the amounts attributed to “Church                  
          Anniversary”, “Pastor’s Appreciation”, and “Building Fund”,                 
          totaling $2,100, are nondeductible.                                         





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