Paul Christopher and Kandl Lei Robinson - Page 7




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          provided an acknowledgment of a $2,100 contribution to the                  
          Colesville Council of Community Congregations.  It is not clear             
          whether the purported contribution was cash or noncash, since the           
          receipt indicates that $2,100 is the “value according to donor”.            
          As noted supra note 2, petitioners claimed a $2,650 deduction for           
          noncash contributions, which was allowed, and is not at issue.              
          Petitioners did not provide a copy of the Form 8283, Noncash                
          Charitable Contributions, showing that the $2,100 contribution              
          has not already been allowed, and they have otherwise failed to             
          meet the substantiation requirements for a contribution greater             
          than $250.  Based on the foregoing, respondent’s determination is           
          sustained except that petitioners are entitled to an additional             
          $52 deduction above the $1,500 respondent allowed for cash                  
          charitable contributions for 2003.                                          
          Petitioners have otherwise failed to substantiate the                       
          remaining claimed contribution deductions for either year.                  
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             under Rule 155.                          














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