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170(f)(8)(A). The deduction for a contribution of property
equals the fair market value of the property on the date
contributed. Sec. 1.170A-1(c)(1), Income Tax Regs.
A taxpayer claiming a charitable contribution is generally
required to maintain for each contribution a canceled check, a
receipt from the donee charitable organization showing the name
of the organization and the date and amount of the contribution,
or other reliable written records showing the name of the donee
and the date and amount of the contribution. Sec. 1.170A-
13(a)(1), Income Tax Regs.
We first consider petitioners’ cash contributions.
Petitioners claimed they donated $111 to Family of Christ Church
in Lakeville, Minnesota, during 2003. Mr. Bogue provided the
name and address of the church and the dates and amounts he or
his wife contributed in a document he prepared himself when he
prepared their tax returns. Petitioners offered no receipts or
acknowledgments from the church. Mr. Bogue testified that he and
his wife were searching for a church and they periodically
attended the Family of Christ Church during 2003, but were not
members or parishioners. Petitioners’ document indicates that
Mr. Bogue or Mrs. Bogue or both attended the church 17 times
during the year and contributed between $5 and $20 at each
6(...continued)
1217, 120 Stat. 1080.
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Last modified: November 10, 2007