Darin Warfield and Sharon Hardin - Page 6

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          or, in the absence of a check or receipt; (3) other reliable                
          written records.  Sec. 1.170A-13(a)(1), Income Tax Regs.                    
               For a contribution of property other than money, taxpayers             
          must maintain, for each contribution, a receipt showing the name            
          of the donee, the date and location of the contribution, and a              
          description of the property.  Sec. 1.170A-13(b)(1), Income Tax              
          Regs.  Where it is impractical to obtain a receipt, taxpayers               
          must maintain other written records indicating the name and                 
          address of the donee, the date and location of the donation, a              
          description of the property, and its fair market value at the               
          time the contribution was made.  Id.; sec. 1.170A-13(b)(2)(ii),             
          Income Tax Regs.                                                            
               Section 1.170A-13(a)(2)(i), Income Tax Regs., which applies            
          to both money and property contributions, provides special rules            
          to determine the reliability of records on the basis of all the             
          facts and circumstances of the particular case and further                  
          provides factors to consider in making this determination,                  
          including:  (1) Whether the writing that evidences the                      
          contribution was written contemporaneously and (2) whether the              
          taxpayer keeps regular records of the contributions.5                       
               Petitioners produced no canceled checks or receipts of their           
          cash contributions that are still at issue.  The only records               

               5 Sec. 1.170A-13(b)(2)(i), Income Tax Regs., provides that             
          the reliability rules for records of money contributions also               
          apply to records of property contributions.                                 





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