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RECEIPT, RECORDKEEPING, AND REPORTING REQUIREMENTSthe size of the gift. Preferably, the record will be a cancelled check or a receiptfrom the charitable donee. 1 Otherwise, the record must be written and reliable. 2The record must show the name of the charitable donee, the date of the contribution,and the amount of the contribution. 3A letter or other communication from the charitable donee acknowledgingreceipt of the contribution, and showing the date and amount of the contribution,constitutes a receipt. 4 A donor has the burden of establishing reliability of awritten record other than a check or receipt. The reliability of this type of writtenrecord is determined on the basis of all of the facts and circumstances of a particularcase. Factors indicating that this other written evidence is reliable include:• The contemporaneous nature of the writing that evidences the contribution• The regularity of the donor’s recordkeeping procedures• In the case of a contribution of a “small amount” (that term is notdefined), any other written evidence from the recipient charitable organizationevidencing the making of a gift that would not otherwise constitutea receipt 5As to the second of these factors, a “contemporaneous diary entry statingthe amount and date of the donation and the name of the donee charitable organizationmade by a taxpayer who regularly makes such diary entries would generallybe considered reliable.” 6 As to the third of these factors, the evidencewould include an “emblem, button, or other token traditionally associated witha charitable organization and regularly given by the organization to personsmaking cash donations.” 71 Reg. § 1.170A-13(a)(1)(i), (ii).2 Reg. § 1.170A-13(a)(1)(iii).3 Id.4 Reg. § 1.170A-13(a)(1)(ii).5 Reg. § 1.170A-13(a)(2)(i).6 Reg. § 1.170A-13(a)(2)(i)(B).7 Reg. § 1.170A-13(a)(2)(i)(C). A court denied a charitable deduction to an individual who claimed to havegiven $12,000 in a year to a church out of an income of less than $29,000; the individual did not have anydocumentation of the purported gifts and the court found this extent of giving to be “inherently incredible.”Purnell v. Commissioner, 66 T.C.M. (CCH) 1587, 1588 (1993). Other cases in which the charitable deductionwas denied, in whole or in part, because of lack of substantiation are Hart v. Commissioner, 73 T.C.M.(CCH) 1684 (1997); Novick v. Commissioner, 72 T.C.M. (CCH) 1615 (1996); Bradley v. Commissioner, 72T.C.M. (CCH) 1001 (1996); Mohiuddin v. Commissioner, 72 T.C.M. (CCH) 659 (1996); Roberts v. Commissioner,71 T.C.M. (CCH) 3007 (1996); Patterson v. Commissioner, 71 T.C.M. (CCH) 2540 (1996); McCannv. Commissioner, 71 T.C.M. (CCH) 2403 (1996); Callahan v. Commissioner, 71 T.C.M. (CCH) 2103 (1996);Brown v. Commissioner, 71 T.C.M. (CCH) 1974 (1996); Jackson v. Commissioner, 70 T.C.M. (CCH) 1061(1995); Shackelford v. Commissioner, 70 T.C.M. (CCH) 945 (1995); Lussy v. Commissioner, 70 T.C.M.(CCH) 427 (1995); Lattin v. Commissioner, 69 T.C.M. (CCH) 2734 (1995); Paige v. Commissioner, 68T.C.M. (CCH) 1531 (1994); Burrell v. Commissioner, 68 T.C.M. (CCH) 1237 (1994); Osborne v. Commissioner,68 T.C.M. (CCH) 273 (1994); Strong v. Commissioner, 68 T.C.M. (CCH) 203 (1994); Park v. Commissioner,68 T.C.M. (CCH) 184 (1994); Simmons v. Commissioner, 67 T.C.M. (CCH) 2979 (1994); CMEM,Inc. v. Commissioner, 66 T.C.M. (CCH) 1241 (1993); Chandler v. Commissioner, 66 T.C.M. (CCH) 1214(1993); Hooks v. Commissioner, 66 T.C.M. (CCH) 797 (1993); Kuhl v. Commissioner, 66 T.C.M. (CCH) 278(1993); Manning v. Commissioner, 65 T.C.M. (CCH) 2221 (1993); Cheh v. Commissioner, 64 T.C.M. (CCH)1291 (1992); Jones v. Commissioner, 64 T.C.M. (CCH) 521 (1992); Purnell v. Commissioner, 63 T.C.M.(CCH) 3037 (1992); DiCarlo v. Commissioner, 63 T.C.M. (CCH) 3015 (1992); Taylor v. Commissioner,63 T.C.M. (CCH) 2514 (1992); Anderson, Jr. v. Commissioner, 63 T.C.M. (CCH) 2278 (1992); Noah v.Commissioner, 63 T.C.M. (CCH) 1761 (1992); Gallentine v. Commissioner, 63 T.C.M. (CCH) 1747 (1992); 582