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Turning to the value of petitioners’ donation to the
Salvation Army, we note that petitioners have provided a receipt
from the Salvation Army, dated November 21, 2003, reflecting the
donation of three boxes containing clothing and toys. However,
by failing to state whether the Salvation Army provided any goods
or services in exchange for a contribution that petitioners claim
exceeded $250, the receipt fails to satisfy section
170(f)(8)(B)(ii). Although we believe that it is unlikely that
petitioners received any goods or services from the Salvation
Army in exchange for their donation, we are required to apply the
statute and cannot escape its clear command. Weyts v.
Commissioner, T.C. Memo. 2003-68 (“To allow petitioner the
charitable contribution deduction in the circumstances here would
contravene the specific statutory language and purpose of
recordkeeping for contributions in excess of $250.”); see also
Kendrix v. Commissioner, T.C. Memo. 2006-9. Accordingly,
petitioners have not demonstrated entitlement to a deduction in
excess of the $25 that respondent has allowed for their
charitable contribution of property to the Salvation Army.
IV. Unreimbursed Employee Business Expenses
Section 162(a) authorizes a deduction for “all the ordinary
and necessary expenses paid or incurred during the taxable year
in carrying on any trade or business”. However, taxpayers are
generally barred from deducting the daily cost of commuting to
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