Tax Court Reminder: Proper Documentation Required for Charitable Contribution Donations

A recent Tax Court decision should stand to remind taxpayers that proper documentation is required for charitable contributions--particularly for high-value contributions of non-cash items.  The case was Cade v. Commissioner, T.C. Memo 2025-20, where the taxpayers claimed a charitable contribution deduction of $284,553, all for non-cash items (specifically, jackets, coveralls, granite cobblestones, vinyl tile and adhesive).  When the IRS requested copies of their qualified appraisals and contemporaneous written acknowledgements (CWAs), the taxpayers provided Forms 8283 stating that the forms were acknowledged by the receiving party and "signed by the appraiser of the respective gifted property.”  After making a second request for the required CWAs, qualified appraisals and information related to how the appraisals were qualified, the taxpayers produced letters from the appraisals and letters from the church (the beneficiary of the gifts) with illegible signatures and no indication of the signing party's name or contact information.  The Tax Court granted the IRS' motion for summary judgement, agreeing that the taxpayers had failed to provide the required qualified appraisals.  The court did, however, find that factual questions exist with respect to the validity of the CWAs.  For more information on the substantiation requirements for non-cash charitable donations, visit Tax Facts Online. Read More: Link to Q8061.