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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 a qualified donee organization.7 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 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.
We first consider petitioner’s cash contributions.
Petitioner claimed he donated $225 to his hometown church during
2003. Petitioner provided the name and address of the church and
the dates and amounts he contributed in a document he prepared
7There 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.
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Last modified: November 10, 2007