- 4 - Petitioners also attached a form entitled “Itemized Gifts and Donations to the Salvation Army” to their return. On this form, petitioners listed the value of the items donated to the Salvation Army as follows: Items Value 25 Jackets $1900 256 Clothes 5601 110 Pair [sic] of shoes 2485 45 Fashion bags 1588 10 Irons and boards 200 30 Backpacks 255 Furniture 5560 20 Household appliances 300 Total $17,889 With respect to the aforementioned items, petitioners did not attach a Form 8283, Noncash Charitable Contributions, or any other statement of appraisal to their return. Respondent issued petitioners a notice of deficiency in January 2006. Respondent disallowed in full the claimed deductions and determined a $4,283 deficiency in petitioners’ 2003 income tax. Petitioners filed a petition for review of respondent’s determination. Petitioners resided in Shorewood, Wisconsin, when their petition was filed. Discussion Deductions are a matter of legislative grace and are allowed only as specifically provided by statute. INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934). Generally, the taxpayerPage: Previous 1 2 3 4 5 6 7 8 9 10 NextLast modified: November 10, 2007