- 8 - contributions of $250 or more under section 170(a), whether cash or property, must be substantiated by a contemporaneous written acknowledgment of the contribution by the donee organization. Sec. 170(f)(8). The contribution logs are neither receipts nor acknowledgments prepared by the donee organization. The receipts and contribution logs do not meet the substantiation requirements of section 1.170A-13(b)(1), Income Tax Regs., nor do they meet the heightened substantiation requirements of section 170(f)(8).6 Respondent’s determination as to the claimed noncash charitable contributions is sustained. II. Miscellaneous Itemized Deductions On his 2003 Schedule A, petitioner reported unreimbursed employee expenses totaling $20,916. After accounting for the 2-percent floor of section 67(a), petitioner claimed a miscellaneous itemized deduction of $19,552. Respondent disallowed all of the miscellaneous itemized deductions because petitioner did not prove to respondent that he paid or incurred the expenses in 2003 or that the expenses were 5(...continued) time of the donation. Sec. 1.170A-13(b)(2)(ii), Income Tax Regs. 6 Petitioner told his return preparer that he donated used clothes and furniture in 2003. However, he had no idea how his return preparer arrived at the deduction claimed in the amount of $4,950; “when I saw the 4,000 I couldn’t phantom [sic] donating 4,000 worth of clothes.”Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 NextLast modified: March 27, 2008