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U.S. 435, 440 (1934). Section 170(a) allows as a deduction any
charitable contribution the payment of which is made within the
taxable year. Deductions for charitable contributions are
allowable only if verified under regulations prescribed by the
Secretary. Sec. 170(a)(1). In general, the regulations require
a taxpayer to maintain for each contribution of money one of the
following: (1) A canceled check; (2) a receipt from the donee;3
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
3 A receipt is required to contain the name of the donee,
the date of the contribution, and the amount of the contribution.
Sec. 1.170A-13(a)(1), Income Tax Regs.
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Last modified: May 25, 2011