Kim H. Barnes - Page 6




                                        - 6 -                                         
               Petitioner also claimed an itemized deduction for charitable           
          contributions of property other than money of $1,841.  See sec.             
          1.170A-13(b), Income Tax Regs.  To substantiate the deduction,              
          petitioner introduced into evidence receipts allegedly issued by            
          the Purple Heart Service Foundation (the foundation), indicating            
          petitioner donated various items of furniture to the foundation             
          during 2002.  While the receipts indicate various contribution              
          dates in 2002, the form for the receipts indicates a form                   
          revision date of February 2004.  Petitioner explained that she              
          lost the original receipts in the basement flood, and she went              
          back to the foundation to obtain new receipts.  Petitioner                  
          testified that she told someone at the foundation what she                  
          donated, and the person at the foundation filled in the receipts            
          according to what petitioner said.  Petitioner could not explain            
          how she determined the dates of contribution shown on the                   
          receipts and even testified that some of the donations were made            
          in 2001.  We do not find the receipts to be reliable, as the                
          person at the foundation simply put down the items petitioner               
          told him to and the dates bear no relationship to when the                  
          alleged contributions were made.  See sec. 1.170A-13(b)(1) and              
          (2), Income Tax Regs.  We hold that petitioner is not entitled to           
          an itemized deduction for charitable contributions of property              
          other than money.                                                           








Page:  Previous  1  2  3  4  5  6  7  Next 

Last modified: November 10, 2007