- 5 - 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 therePage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011