Christiana Stamoulis - Page 9

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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