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apparently reasoned that for charitable contributions of less
than $250, it follows that a written acknowledgment from the
donee organizations was not required.
Petitioner’s reliance solely on section 170(f)(8) is
misplaced because that section merely makes more stringent the
substantiation requirements for any charitable contribution of
$250 or more. The substantiation rules governing all cash
contributions are set forth under section 1.170A-13(a)(1), Income
Tax Regs. The regulations provide that if the taxpayer makes a
charitable contribution of money, the taxpayer must maintain for
each contribution either a canceled check, a receipt, a letter or
other communication from the donee charitable organization, or
other reliable written records showing the name of the donee, the
date of the contribution, and the amount of the contribution.
See Bradley v. Commissioner, T.C. Memo. 1996-461 (disallowing
deductions for cash gifts that were not substantiated by canceled
checks or receipts); Hammann v. Commissioner, T.C. Memo. 1996-160
(same); sec. 1.170A-13(a)(1), Income Tax Regs.
Petitioner did not present any receipts or documentation
from the donee charitable organizations. Petitioner is therefore
not entitled to deductions for cash contributions in excess of
the amount respondent conceded.
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