Personal Income Tax Planning

This week our Podcast considers the Tax Court's application of the charitable documentation regulations to two real world cases. In the case of Kendrix v. Commissioner a former IRS CID employee and Revenue Officer is found to be lacking in the documentation for her many charitable contributions. While there appears to be reason for the court to believe the contributions to be overstated or not made at all, the court actually keeps returning to technical inadequacies in her documentation to actually deny the deductions. The judge even muses that the court may have erred in the past in allowing the use of the Cohan rule to be used when documentation didn't meet the requirements, but ultimately concludes that the issue doesn't have to be dealt with in this case case. That makes this case potentially troubling since that same logic would apply even if there was no question the donation was made. The second case is a Tax Court Summary opinion of Haas v. Commissioner where the court, among other things, get