Darryl R. and Kristi L. Stephens - Page 13




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          organization.6  Sec. 170(f)(8)(A).  The deduction for a                     
          contribution 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 deduction is             
          generally required to maintain for each contribution a canceled             
          check, a receipt from the donee charitable organization showing             
          the name of the organization and the date and amount of the                 
          contribution, or other reliable written records showing the name            
          of the donee and the date and amount of the contribution.  Sec.             
          1.170A-13(a)(1), Income Tax Regs.                                           
               Petitioners assert they are entitled to a charitable                   
          contribution deduction.  Petitioners reported on the return for             
          2003 that they acquired personal property on January 1, 1920,7              
          for $2,000, which they donated to the Salvation Army in                     
          Minneapolis, Minnesota.  At trial, however, petitioners provided            


               6There 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 contributions made in tax years beginning after Aug. 17,                
          2006.  Pension Protection Act of 2006, Pub. L. 109-280, sec.                
          1217, 120 Stat. 1080.                                                       
               7We assume petitioners made an error on Form 8283, Noncash             
          Charitable Contributions, when they claimed that they acquired              
          the property they donated on Jan. 1, 1920, a date before                    
          petitioners were born.                                                      





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