- 31 - for the noncash charitable contributions because they substantially complied (that the information provided is sufficient to meet the requirements) and because they had “reasonable cause * * * for [any] failure to fully comply.” A charitable contribution is allowable as a deduction only if verified under regulations prescribed by the Secretary. Sec. 170(a)(1); Hewitt v. Commissioner, 109 T.C. 258, 261 (1997), affd. without published opinion 166 F.3d 332 (4th Cir. 1998). The obligation to substantiate charitable contribution deductions is clear and unambiguous. Blair v. Commissioner, T.C. Memo. 1988-581. No deduction is allowed for a contribution in excess of $5,000 unless the taxpayer meets the substantiation requirements of section 1.170A-13(c)(2), Income Tax Regs. Todd v. Commissioner, 118 T.C. 334, 340 (2002); sec. 1.170A- 13(c)(1)(i) Income Tax Regs. Section 1.170A-13(c)(2)(i), Income Tax Regs., generally provides that a taxpayer must comply with the following three requirements: (A) Obtain a qualified appraisal (as defined in paragraph (c)(3) of this section) for such property contributed. If the contributed property is a partial interest, the appraisal shall be of the partial interest. (B) Attach a fully completed appraisal summary (as defined in paragraph (c)(4) of this section) to the tax return (or, in the case of a donor that is a partnership or S corporation, the information return) on which the deduction for the contribution is first claimed (or reported) by the donor. (C) Maintain records containing the information required by paragraph (b)(2)(ii) of this section.Page: Previous 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 NextLast modified: March 27, 2008