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We do not accept petitioner’s testimony as a reasonable
basis to estimate his cash charitable contributions.
Respondent’s determination as to the claimed cash charitable
contributions is sustained.
Petitioner claimed a deduction of $4,950 for noncash
charitable contributions. To substantiate his noncash charitable
contributions, petitioner provided copies of two receipts from
the Salvation Army and two self-prepared logs. One of the
receipts does not state the date on which the property was
contributed. The other receipt indicates that the contribution
was made on May 4, 2006. Neither receipt contains the value of
the items contributed.
To verify a charitable contribution for property other than
money, the regulations require the taxpayer to maintain a receipt
from the donee for each contribution showing the following: (1)
The name of the donee; (2) the date and location of the
contribution; and (3) a description of the property in detail
reasonably sufficient under the circumstances. Sec. 1.170A-
13(b)(1), Income Tax Regs. Where it is “impractical” to obtain a
receipt, the taxpayer must maintain “reliable written records” of
the noncash contributions.5 See id. However, deductions for
5 A reliable written record for purposes of substantiating a
noncash contribution shall contain the name and address of the
donee, the date and location of the contribution, a description
of the property, and the fair market value of the property at the
(continued...)
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