- 6 -
written acknowledgment must include “The amount of cash and a
description (but not value) of any property other than cash
contributed.” In addition, the written acknowledgment must
state, among other things, “Whether the donee organization
provided any goods or services in consideration, in whole or in
part” for the contribution. Sec. 170(f)(8)(B)(ii). Finally, a
taxpayer deducting a charitable contribution, regardless of its
amount, 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.
In support of the claimed $2,096 in cash donations to their
church, petitioners have offered the aforementioned self-prepared
list of the contributions and the dates on which they were made,
along with letters from elders of their church stating that
petitioners attend church regularly and participate in church
programs.4
Notwithstanding the Court’s discretionary authority pursuant
to Cohan, a taxpayer must provide the Court with some basis upon
4 Mr. Claborn claims to have made these donations in 44
separate “Church Offering” installments ranging from $25 to $60,
42 separate $2 donations for “Lee Anderson’s Class,” and 42
separate $2 donations and a single $1 donation for “Children’s
Class.”
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: November 10, 2007