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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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Last modified: May 25, 2011