- 5 -
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.
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011