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property to charitable organizations in 2003. Charitable
contributions are generally deductible under section 170(a). No
deduction is allowed, however, for any contribution of $250 or
more unless the taxpayer substantiates the contribution by a
contemporaneous written acknowledgment of the contribution by a
qualified donee organization. Sec. 170(f)(8)(A). The deduction
for a contribution of property equals its fair market value on
the date contributed. Sec. 1.170A-1(c)(1), Income Tax Regs.
A taxpayer claiming a charitable contribution of money is
generally required to maintain for each contribution a canceled
check, a receipt from the donee charitable organization showing
the name of the organization and the date and amount of the
contribution, or other reliable written records showing the name
of the donee and the date and amount of the contribution. Sec.
1.170A-13(a)(1), Income Tax Regs.
We first consider petitioners’ cash contributions.
Petitioners claimed they donated to their hometown church in 2003
and introduced a list they created with the name and address of
the church and the dates and amounts of contributions, totaling
$464.6 Petitioners did not use the numbered envelopes provided
by the church that would have allowed the church to verify and
6The remaining balance of the $2,575 claimed cash donations
appears not to be a donation of cash at all, but the videotapes
Mr. Wasik claims to have purchased and allowed Prior Lake
Athletics for Youth (P.L.A.Y.) coaches to view.
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Last modified: November 10, 2007