Robert and Cheryl McKeown - Page 17

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          Charitable Contributions                                                    
               We finally consider petitioners’ charitable contributions.             
          Petitioners claimed they contributed property worth $3,014 to               
          charitable organizations in 2003.                                           
               Charitable contributions are generally deductible under                
          section 170(a).  No deduction is allowed, however, for any                  
          contribution of $250 or more unless the taxpayer substantiates              
          the contribution by a contemporaneous written acknowledgment of             
          the contribution by a qualified donee organization.5  Sec.                  
          170(f)(8)(A).  The deduction for a contribution of property                 
          equals its fair market value on the date contributed.  Sec.                 
          1.170A-1(c)(1), Income Tax Regs.                                            
               Petitioners provided no documentation, substantiation, or              
          testimony concerning their contributions of property for 2003.              
          Petitioners are therefore not entitled to deduct any amount for             
          charitable contributions of property.                                       

               5There are now stricter requirements for contributions of              
          money.  Sec. 170(f)(17).  No deduction for a contribution of                
          money in any amount is allowed unless the donor maintains a bank            
          record or written communication from the donee showing the name             
          of the donee organization, the date of the contribution, and the            
          amount of the contribution.  Id.  This new provision is effective           
          for contributions made in tax years beginning after Aug. 17,                
          2006.  Pension Protection Act of 2006, Pub. L. 109-280, sec.                
          1217, 120 Stat. 1080.                                                       

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