Gregory S. Robinette - Page 7

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          1.   Gifts to Charity                                                       
               As previously stated, on petitioner’s Schedule A filed with            
          his Federal income tax return for taxable year 2002, he reported            
          the following gifts to charity:                                             
               Itemized Deductions                     Amount                         
               Gifts by cash or check                  $2,600                         
               Gifts other than by cash or check       460                            
                    Total gifts                        $3,060                         
               Respondent determined that petitioner did not adequately               
          substantiate that any of the claimed gifts to charity were made.            
          Accordingly, respondent disallowed the total amount of                      
          petitioner’s claimed gifts to charity.                                      
               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.                                                   
               The applicable regulations require a taxpayer to maintain              
          for each contribution of money a canceled check, a receipt from             
          the donee organization showing the date and amount of the                   
          contribution, or other reliable written records showing the name            
          of the donee and the date and amount of the contribution.  See              
          sec. 1.170A-13(a)(1), Income Tax Regs.  For charitable                      
          contributions of property other than money, taxpayers generally             
          must maintain for each contribution a receipt from the donee                






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