Governance & Nonprofit Best Practices

Court Denies Charitable Deduction for Lack of Proper Documentation

A recent Tax Court case (Besaw, T.C. Summary Opinion 2025-7) is a reminder that good intentions aren’t enough when it comes to claiming charitable deductions.

In this case, a Washington man claimed a $6,760 deduction for noncash charitable contributions in 2019. While the court believed he did make the donations, his deduction was denied because he didn’t meet IRS substantiation requirements under IRC §170(a)(1).

Key Takeaways for Nonprofits & Donors:
Contemporaneous documentation matters – Receipts must include the charity’s name, date, location, and a description of the donated items.
Over $250? – You need a written acknowledgment from the charity at the time of the donation.
Over $500? – Keep records showing how/when the property was acquired and its cost or basis.
Reconstructed lists after the fact don’t count – Documentation must be in place at the time of the gift.

Even though the IRS later dropped the accuracy-related penalty, the taxpayer still lost the deduction—proof that recordkeeping is just as important as generosity.

📌 Bottom line: If you’re donating noncash items, make sure you have all required documentation before filing your return.

Dr. Beckham has over 19 years of experience in nonprofit tax consulting. She is passionate about providing clients with valuable insights into how they can stay true to their missions and maintain their tax-exempt status. She focuses on federal and state tax planning and compliance for public charities, private foundations, and other tax-exempt organizations. Dr. Beckham has provided tax consulting and annual compliance services to hundreds of nonprofit organizations. She also performs tax planning, analysis, and research to help clients determine appropriate resolutions to their tax issues.