Robert A. White - Page 7

                                        - 6 -                                         
               Petitioner testified that in an average year he contributed            
          approximately $100 to the Combined Federal Campaign (CFC) and               
          that it was possible that he did so in 2003.  His practice was to           
          write a check to CFC, and the reason for his uncertainty about              
          2003 was his lack of a canceled check.  He further stated that he           
          normally contributes $20 each time he goes to church and that he            
          probably attended church “maybe three times in 2003.”                       
          Petitioner’s testimony was vague and uncertain.                             
               In general, the regulations require the taxpayer to maintain           
          one of the following for each contribution of money:  (1) A                 
          canceled check; (2) a receipt from the donee; or (3) in the                 
          absence of a check or receipt, other reliable written records.3             
          Sec. 1.170A-13(a)(1), Income Tax Regs.  The taxpayer must                   
          establish the reliability of the written records.  Sec. 1.170A-             
          13(a)(2)(i), Income Tax Regs.  Any contribution of $250 or more             
          shall not be allowed unless the taxpayer substantiates the                  
          contribution by a contemporaneous written acknowledgment of the             
          contribution by the donee organization.4  Sec. 170(f)(8).                   

               3 Both receipts and reliable written records should include            
          the name of the donee, the date of the contribution, and the                
          amount of the contribution.  Sec. 1.170A-13(a)(1)(ii) and (iii),            
          Income Tax Regs.                                                            
               4 The written acknowledgment must state the amount of cash             
          and a description (but not necessarily the value) of any property           
          other than cash the taxpayer donated and also whether the donee             
          provided any consideration to the taxpayer.  Sec. 1.170A-                   
          13(f)(2), Income Tax Regs.                                                  

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next 

Last modified: March 27, 2008