- 48 - Our review of the materials and information that petitioners submitted to respondent with their returns reveals that important information that would have enabled respondent to understand and monitor the claimed contributions was not supplied. Congress mandated the reporting information so that the Internal Revenue Service (IRS) could monitor and address congressional concerns about overvaluation and other aspects of claimed charitable contribution deductions. The submission of the information is prerequisite to petitioners’ entitlement to a charitable contribution deduction. Petitioners’ failure to substantially comply or otherwise provide respondent with sufficient information to accomplish the statutory purpose compels our conclusion that respondent properly disallowed petitioners’ claimed noncash charitable contribution deductions.4 Section 183 Activities Rance and Zane each claimed losses that respondent disallowed as being from activities not engaged in for profit within the meaning of section 183. If an individual engages in an activity but does not engage in that activity for profit, “no deduction attributable to such activity shall be allowed under this chapter except as provided in * * * [section 183].” Sec. 183(a). Section 183(b)(1) permits deductions which are otherwise 4 Our holding that petitioners are not entitled to the noncash charitable contribution deduction renders it unnecessary to decide the value of the contributed interests.Page: Previous 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 NextLast modified: March 27, 2008