James A. and Joan H. Soholt - Page 8




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          canceled checks.  Petitioners also claimed they contributed                 
          property worth $3,492 to charitable organizations in 2003, and              
          respondent allowed $89.                                                     
               Charitable contributions a taxpayer makes are generally                
          deductible under section 170(a).  No deduction is allowed,                  
          however, for any contribution of $250 or more unless the taxpayer           
          substantiates the contribution by a contemporaneous written                 
          acknowledgment of the contribution by the qualified donee                   
          organization.4  Sec. 170(f)(8)(A).  The deduction for                       
          contributions of property equals the fair market value of the               
          property on the date contributed.  Sec. 1.170A-1(c)(1), Income              
          Tax Regs.                                                                   
               A taxpayer claiming a charitable contribution is generally             
          required to maintain for each contribution a canceled check, some           
          communication from the donee organization acknowledging receipt             
          of a contribution and showing the date and amount of the                    
          contribution, or other reliable written records showing the name            
          of the donee, along with the date and amount of the contribution.           
          Sec. 1.170A-13(a)(1)(i) to (iii), Income Tax Regs.                          


               4There are now stricter requirements for contributions of              
          money.  Sec. 170(f)(17).  No deduction for a contribution of                
          money in any amount is allowed unless the donor maintains a bank            
          record or written communication from the donee showing the name             
          of the donee organization, the date of the contribution, and the            
          amount of the contribution.  Id.  This new provision is effective           
          for tax years beginning after Aug. 17, 2006.  Pension Protection            
          Act of 2006, Pub. L. 109-280, sec. 1217, 120 Stat. 1080.                    






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