- 16 - constituted a separate trade or business, the section 179 deduction would not be allowable because petitioner did not have any income from the sale of the book in 2003.8 Respondent properly disallowed the claimed deduction under section 179. Petitioner claimed a deduction of $7,250 for charitable contributions--$7,050 of which was for contributions of property and $200 was for cash contributions. Respondent disallowed all of the deduction for cash contributions and all but $500 of the deduction for contributions of property. Section 170 allows a deduction for charitable contributions during the taxable year if they are verified as provided in the regulations. Sec. 170(a)(1). No deduction is allowed for any contribution of $250 or more unless the taxpayer substantiates the contribution by a contemporaneous written acknowledgment of the contribution by the qualified donee organization. Sec. 170(f)(8)(A). This written acknowledgment must state the amount of cash and a description (but not necessarily the value) of any property other than cash the taxpayer donated and whether any consideration was given to the taxpayer. Sec. 1.170A-13(f)(2), Income Tax Regs. 8Furthermore, petitioner failed to substantiate the portion of the use of the vehicle that could be attributed to business rather than personal use.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 NextLast modified: November 10, 2007