Only seven (count ’em, seven) small-claimer T. C. Sum. Op.s as we near the end of month seven of 2025. In contrast, CSTJ Zachary S. (“High-Rise”) Fried has issued thIs date 96 (count ’em, 96) SPTOs for small-claimers. How many ya think CSTJ High-Rise Fried will actually try?

STJ Jennifer E. (“Publius”) Sigel has John Henry Besaw, T. C. Sum. Op. 2025-7, filed 7/21/25, a simple Section 170 noncash, definitely not Dixieland Boondockery.

John Henry “…stated that it was his understanding that the elements required by law for noncash charitable contribution deductions were to include the name and address of the donee organization and the description of donated property, not anything about the value of the donated items. He contends that is why he did not include the values of the donated items on his [year-at-issue] tax return. Petitioner did not testify, and the Court does not find that it was impractical to obtain receipts for the donated items that included descriptions of the items donated.

“Although the Court believes petitioner donated items to charitable organizations in [year-at-issue], the record before the Court shows that petitioner did not satisfy the substantiation requirements of section 170(a)(1) and Treasury Regulation § 1.170A-13. Regardless of whether petitioner met the requirements for deducting charitable contributions of $250 or more, or for deducting charitable contributions of property valued in excess of $500, none of the receipts he provided from the charitable organizations for his donations included any descriptions of the donated items; therefore, petitioner is not  entitled to deduct noncashcharitable contributions for tax year 2019. See I.R.C. § 170; Treas. Reg. § 1.170A-13(b)(1).” T. C. Sum. Op. 7, at pp. 5-6.