Robert A. White - Page 8

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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           

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