Conrad Fitzgerald Lewis - Page 23

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          charitable contributions for taxable year 2000 in the amount of             
               Deductions for charitable contributions are allowable only             
          if verified under regulations prescribed by the Secretary.  Sec.            
          170(a).  Section 1.170A-13, Income Tax Regs., in turn, sets forth           
          the types of substantiation necessary to support deductions for             
          charitable contributions.                                                   
               For charitable contributions of property other than money,             
          taxpayers generally must maintain for each contribution a receipt           
          from the donee showing the following information:  (1) The name             
          of the donee; (2) the date and location of the contribution; and            
          (3) a description of the property in detail reasonably sufficient           
          under the circumstances.  Sec. 1.170A-13(b)(1), Income Tax Regs.            
          The amount of the contribution is the fair market value of the              
          property at the time of the contribution.  Sec. 1.170A-1(c)(1),             
          Income Tax Regs.                                                            
               Petitioner provided no documentation that would substantiate           
          that his claimed “gifts other than by cash or check” were made or           
          the fair market value of such alleged gifts.  Furthermore,                  
          petitioner did not give any testimony as to any specific                    
          charitable gifts.  On the basis of the record in this case, we              
          conclude that petitioner has not substantiated any charitable               
          gifts for taxable year 2000 other then those already allowed by             

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