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the relevant facts and circumstances. See sec. 1.170A-13(a)(2),
Income Tax Regs.
If the donation is a small amount, any written or other
evidence from the donee charitable organization acknowledging
receipt is generally sufficient. See sec. 1.170A-13(a)(2)(i)(C),
Income Tax Regs. On the other hand, with respect to a deduction
exceeding $500 for a charitable contribution of property,
additional information is required to support such a deduction.
Specifically, the taxpayer must also maintain written records
establishing: (1) The item’s manner of acquisition as well as
either the item’s approximate date of acquisition or the
approximate date the property was substantially completed and (2)
the cost or other basis, adjusted as provided by section 1016, of
property donated by the taxpayer during the taxable year. Sec.
1.170A-13(b)(3)(i)(A) and (B), Income Tax Regs.
Set against these standards, we first consider petitioner’s
claim with regard to cash donations. As noted above, respondent
now agrees that, during the year in issue, petitioner made cash
donations totaling $1,053. Petitioner has failed to produce
substantiating evidence that would allow for a greater amount.
Consequently, the portion of petitioner’s allowable charitable
contribution deduction for 2002 that is attributable to cash
donations is limited to the amount allowed by respondent.
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Last modified: May 25, 2011