Leonard Stockwell - Page 19




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          on his tax return that he acquired the donated property on                  
          January 1, 2000, for $1,450.                                                
               Petitioner introduced no documentation to support the claim            
          on his return that he acquired the property on January 1, 2000.             
          Petitioner also did not introduce evidence that shows the price             
          he paid when he acquired the property.  Indeed, petitioner                  
          testified that he actually acquired the donated items over time.            
               Petitioner’s documentation regarding the donation of                   
          property is also inconsistent with other evidence in the record.            
          For example, petitioner’s calendar indicates that he was working            
          in Detroit, Michigan, on December 24, 2003, the day of the                  
          purported donation.  Petitioner speculated that he may have left            
          Detroit at 4 a.m. that morning, driven approximately 10 hours to            
          Minnesota, and brought the donated property to Goodwill before              
          Goodwill closed on Christmas Eve.  We decline to accept                     
          petitioner’s speculative explanation and find that petitioner has           
          not substantiated that he made charitable contributions of                  
          property in 2003, let alone property worth $924.  Petitioner is             
          therefore not entitled to deduct any amount for charitable                  
          contributions of property.                                                  
               To reflect the foregoing and the concessions of the parties,           

                                                  Decision will be entered            
                                             under Rule 155.                          








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