- 9 - Regs. Under the applicable provisions, a taxpayer claiming a charitable contribution deduction is required to maintain for each contribution a canceled check, some communication from the donee organization acknowledging receipt of a contribution and showing the date and amount of the contribution, or other reliable written records showing the name of the donee, along with the date and amount of the contribution. Sec. 1.170A- 13(a)(1)(i) to (iii), Income Tax Regs. At trial, petitioner testified that he regularly made cash contributions to the church where he and his former girlfriend attended services. He admitted he did not go to church every Sunday but claimed his cash contributions for the year 2002 totaled $3,860. Additionally, petitioner testified that he donated two Sony Playstations to the church constituting the $500 portion of the charitable contributions made other than by cash or check. Petitioner did not offer any substantiating documents to support his charitable contributions for the year at issue, nor did he maintain records of the amount of his contributions. Notwithstanding the Court’s discretionary authority pursuant to Cohan, a taxpayer must provide some basis upon which an estimate of the amount of a claimed deduction may be made. Vanicek v. Commissioner, supra. Without such a basis, any allowance would amount to unguided largesse. Williams v. United States, 245 F.2dPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011