When a taxpayer makes a charitable donation, he or she must maintain adequate records. Without such records, the taxpayer is not entitled to a charitable deduction under Section 170 of the Internal Revenue Code. This situation occurred in Joyce A. Linzy v. Commissioner because the taxpayer, who ironically owned and operated an income tax return preparation business, was unable to provide proper records.
The taxpayer made charitable contributions to Church 1 and Church 2 in 2007. The contributions to Church 1 totaled $7,500 and were acknowledged by both a letter dated January 1, 2010 and copies of checks, all for amounts greater than $250. The contributions to Church 2 were evidenced by a tithing statement dated January 1, 2010 which acknowledged that the taxpayer donated a total of $2,255 and included several copies of checks, some of which were for amounts less than $250.
For cash donations less than $250,