Festus E. Obiakor and Paulene Harris Obiakor - Page 9




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               Petitioners contend that they made substantial charitable              
          cash contributions in 2003 to St. Jude’s Hospital, Texas                    
          Christian University, and both their church and the churches of             
          their friends, which they attended occasionally.  Petitioners did           
          not provide any receipts, canceled checks, or other written                 
          records for their claimed contributions.  Petitioner testified              
          that he did not have receipts for the contributions that                    
          petitioners made to churches because he did not want to ask the             
          pastor of the church to provide him with a receipt for tax                  
          purposes.  Although petitioners did not provide a receipt for               
          their contribution to Texas Christian University, petitioner                
          testified that he has been a regular contributor to Texas                   
          Christian University for many years and is familiar with the                
          donation process there.                                                     
               Based on the foregoing, we are convinced that petitioners              
          have not established either that they made the contributions                
          purported or that the value of such contribution was $17,889.               
          Moreover, we note that although petitioners could have easily               
          obtained the necessary documentation to support most of the cash            
          contributions that they purportedly made in this case, they did             
          not do so.                                                                  
               Accordingly, because petitioners have failed to comply with            
          the requirements under section 170(a) with respect to noncash               
          contributions and have failed to substantiate any of the claimed            







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