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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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