- 22 - substantiate donations they made and introduced no receipts or acknowledgment from the church of any contributions. The balance of the evidence introduced to substantiate petitioners’ cash contributions relates to Prior Lake Athletics For Youth (P.L.A.Y.). Mr. Wasik testified that he purchased instructional videos and kept them at his home, but that he told the other P.L.A.Y. coaches they were free to use the videos. Mr. Wasik acknowledged that he did not donate money to the organization. We are convinced that petitioners attended the church and donated money. We may estimate such cash charitable contributions under the Cohan rule.7 See Fontanilla v. Commissioner, T.C. Memo. 1999-156. We conclude that petitioners are entitled to deduct $400 of cash charitable contributions to the church. Petitioners are not entitled to deduct any amount for cash charitable contributions related to the instructional videos as they acknowledged they did not make any cash contributions to that organization. Moreover, we note that donations must be to the charity. Petitioners may not deduct the costs of videos they purchased as a charitable contribution 7There are now stricter requirements for contributions of money. Sec. 170(f)(17). No deduction for a contribution of money in any amount is allowed unless the donor maintains a bank record or written communication from the donee showing the name of the donee organization, the date of the contribution, and the amount of the contribution. Id. This new provision is effective for contributions made in tax years beginning after Aug. 17, 2006. Pension Protection Act of 2006, Pub. L. 109-280, sec. 1217, 120 Stat. 1080.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 NextLast modified: November 10, 2007