Anthony Muhammad - Page 6

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          contribution was written contemporaneously and (2) whether the              
          taxpayer keeps regular records of the contributions.                        
               Any charitable contribution of more than $250 must further             
          be substantiated by “a contemporaneous written acknowledgment of            
          the contribution by the donee organization”.  Sec. 170(f)(8).               
          “Separate contributions of less than $250 are not subject to the            
          requirements of section 170(f)(8), regardless of whether the sum            
          of the contributions made by a taxpayer to a donee organization             
          during a taxable year equals $250 or more.”  Sec. 1.170A-                   
          13(f)(1), Income Tax Regs.                                                  
               Petitioner testified that because he had made all of his               
          contributions in cash to Muhammad Mosque No. 12, there were no              
          canceled checks.  Petitioner offered no evidence of the specific            
          dates and amounts of the contributions.  Petitioner claimed that            
          he had been given receipts for each contribution made; however,             
          he failed to keep them because he knew he would receive a                   
          statement at the end of the year.  As previously discussed, the             
          only documentation that petitioner offered to substantiate his              
          charitable contributions was an undated list and a recently faxed           
          copy thereof from the Muhammad Mosque No. 12.  Most of the                  
          amounts shown on the documents that petitioner submitted exceed             
          $250.  Petitioner testified that the amounts shown on the                   
          documents are totals and that his contributions were made at                
          various times and in various amounts during the year, but there             






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