Durden v. Comr., T.C. Memo. 2012-140

(petitioners' charitable contribution deduction denied due to failure to strictly comply with substantiation requirements of I.R.C. Sec. 170(f)(8)(A); petitioners contributed $22,517 to their church and statement provided by church acknowledged donated amount, but did not state whether petitioners had received any goods or services in return; upon notice by IRS of problem with church's acknowledgement, petitioners received corrected acknowledgement from church stating that petitioners had not received any goods or services; Tax Court held that first acknowledgement failed due to lack of required statement, and that second acknowledgement failed because it was not received by petitioners before they filed their tax return for year at issue and was, therefore, not contemporaneous as required by Treas. Reg. Sec. 1.170A-13(f)(2)).