Christopher D. and Kristie M. Farran - Page 27

                                       - 27 -                                         
          to the receipt himself.  Petitioners did not introduce any                  
          evidence indicating the specific items petitioners contributed,             
          the estimated value of the items, or the quality of the items.              
               While we are convinced that petitioners donated some items             
          to Goodwill in 2003, petitioners have failed to provide any                 
          evidence of the items they donated or their estimated values.               
          Petitioners are therefore not entitled to deduct any amount for             
          contributions of property to Goodwill Industries in 2003.                   
               Finally, petitioners claim they donated some property to               
          their childrens’ school in 2003.  Petitioners’ tax return for               
          2003 does not indicate what amount petitioners deducted for                 
          property they donated to their childrens’ school.  Petitioners              
          submitted various receipts indicating the purchase of items such            
          as ice cream, Baggies, and peanut butter.  Mr. Farran testified             
          that the donations were made for items used at least partly by              
          petitioners’ children, such as ice cream for their daughter’s               
          school birthday celebration.  These amounts are nondeductible               
          personal expenditures.  Further, petitioners have failed to                 
          substantiate adequately these claimed donations.  Petitioners               
          introduced a letter from the elementary school indicating that              
          petitioners donated some items to their children’s classrooms.              
          Dollar values of the items donated are not provided in the                  
          letter, and the letter is dated September 2006, not                         
          contemporaneously with the contributions.  Moreover, the other              

Page:  Previous  14  15  16  17  18  19  20  21  22  23  24  25  26  27  28  Next 

Last modified: November 10, 2007