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clothing, shoes, women’s handbags, irons and ironing boards,
backpacks, furniture, and household appliances. All of the items
donated to the Salvation Army had been used by petitioners.
Petitioners filed their joint 2003 Federal income tax return
reporting a noncash charitable contribution of $23,211.
Petitioners attached a receipt of the type given by the Salvation
Army to donors for tax purposes to their return.1 Petitioners
listed the following information on the “Special Instructions”
portion of the aforementioned receipt: “boxes of jackets; bags of
clothes; shoes; fashion bags; irons; quantities of backpacks,
furnitures [sic], etc.” Under the “Description” portion of the
receipt, petitioners listed the value of the items donated as
“$17,889.00.”
In addition to the noncash items that they donated to the
Salvation Army, petitioners testified to making the following
cash gifts in taxable year 2003: Texas Christian University
($60); St. Jude’s Hospital ($10); NIWI2 ($250).3 Petitioners did
not provide receipts for any of the aforementioned donations.
1 Petitioner testified that he, and not the Salvation Army’s
staff, filled out the receipt after it was given to him.
2 Based on petitioners’ testimony, “NIWI” is a religious
organization.
3 The record refers to purported noncash and cash
contributions in the amounts of $17,889 and $320, respectively.
The record is silent as to the nature of the unaccounted $5,002
($23,211 – 18,209) in contributions.
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Last modified: November 10, 2007