In Uncategorized on 01/26/2021 at 16:34

There’s yet another contestant in the Taishoff no-prize, sporadic “Good Excuse” sweepstakes, Terry T. Brown, Sr., 2021 T. C. Sum. Op. 4, filed 1/26/21. TT’s tale is told by Judge Travis A. (“Tag”) Greaves, coming on in relief of Judge Ruwe (retired).

It’s a fairly familiar indocumentado. Employed by a “non-profit,” TT pays some unreimbursed expenses for said “non-profit,” but has some problems, even aside from the fact that said “non-profit” is never identified as a Section 501(c)(3) type.

“In support of his position, petitioner submitted a letter from a former [non-profit] board member. The letter stated that petitioner paid out-of-pocket expenses on [non-profit]’s behalf for which he was never reimbursed and that those unreimbursed expenses should be considered contributions to a nonprofit. The letter is dated… nearly a year after the close of the [year at issue] –and does not provide an amount, date, location, or description of any cash or property actually donated. Neither this letter nor any other evidence set forth in the record meets the requirements of the section 170 regulations. Accordingly, petitioner failed to sufficiently show that he incurred such expenses and may not claim a deduction for the disallowed charitable contributions on his [year at issue] Form 1040.” 2021 T.C. Sum. Op. 4, at pp. 13-14.

Now that’s not enough for a sweepstakes entry.  But this is.

“At some point… respondent audited petitioner’s returns for the years at issue. When asked to provide records necessary to substantiate the expenses and losses reported on his Schedules A, C, and E, petitioner claimed that he maintained the supporting documentation exclusively on his [non-profit] work computer, which he no longer had access to following his termination from [non-profit]. Petitioner claimed that he made several attempts to retrieve the files but that [non-profit] informed him that they had been destroyed.” 2021 T. C. Sum. Op. 4, at p. 5.

And we can stop here.


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