James A. and Joan H. Soholt - Page 9




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               We first consider petitioners’ cash contributions.  They               
          were able to substantiate all cash contributions except $232.               
          They failed to introduce any receipts or canceled checks for the            
          remaining $232 cash contributions they claim they made in 2003.             
          Petitioners are therefore not entitled to deduct the additional             
          $232 for cash contributions.                                                
               We next turn to petitioners’ contributions of property.                
          Petitioners introduced receipts indicating they donated clothing            
          and other miscellaneous goods eight times in 2003.  These                   
          receipts do not list the specific items contributed and simply              
          note that petitioners donated a certain number of bags.                     
          Petitioners also introduced a worksheet they prepared when                  
          preparing their tax return that purports to list and value more             
          specifically the items petitioners contributed.  Mr. Soholt                 
          testified that petitioners estimated the value of the clothing              
          they donated at one-half the original cost but also admitted he             
          did not think used clothing was worth half as much as it was                
          worth new.  Petitioners did not introduce any evidence supporting           
          their estimated value or regarding the quality of the donated               
          items that would permit us to estimate its value.                           
               While we are convinced that petitioners donated property to            
          charity in 2003, petitioners have failed to provide any reliable            
          evidence of the items they donated or their values.  Petitioners            
          are therefore not entitled to deduct any additional amount for              







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