Christopher D. and Kristie M. Farran - Page 25

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          and the date and amount of the contribution.  Sec. 1.170A-                  
          13(a)(1), Income Tax Regs.                                                  
               Petitioners claim they contributed property to three                   
          charitable organizations in 2003.  We shall address each claimed            
          contribution in turn.  First, petitioners claim they contributed            
          a 1989 Pontiac Sunbird with a value of $1,750 to Volunteers of              
          America, Inc.  Petitioners introduced a donation receipt from               
          Volunteers of America, Inc. signed by a representative of the               
          organization, that substantiates petitioners indeed donated a               
          1989 Pontiac Sunbird and that petitioners received no goods or              
          services in exchange for the donation.  Petitioners also                    
          introduced a page of the Kelley Blue Book for January-April 2003            
          indicating that the suggested retail for their vehicle was $1,750           
          at the time they donated it.  Respondent introduced evidence                
          indicating that Volunteers of America, Inc. sold the Pontiac                
          Sunbird less than 2 months after it was donated in “as is”                  
          condition for $40.                                                          
               We have carefully examined the evidence presented on this              
          issue.  We discount the evidence that the charitable organization           
          subsequently sold the vehicle for $40 for several reasons.8                 

               8If a charity sells the donated vehicle without any                    
          significant intervening use or material improvement, the                    
          deduction is now limited to the gross proceeds of the sale.  Sec.           
          170(f)(12).  This provision is effective for charitable                     
          contributions made after Dec. 31, 2004.  American Jobs Creation             

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