The income tax regulations specify that a contribution of $250 or more must be substantiated by a receipt from the church or charity that contains all the required information and that is received on or before the earlier of the date the taxpayer filed the return for the year the contribution was made, or the due date, including extensions, for filing the return. In 2009, it is too late for your church to issue a receipt for a 2007 contribution that “cures” the defects in the original receipt.
In a recent letter ruling, the IRS observed that no tax deduction for a charitable contribution of $250 or more is allowed “unless the taxpayer substantiates the contribution by a contemporaneous written acknowledgment of the contribution by the donee organization. If an acknowledgment fails to contain the required information or the taxpayer fails to receive the acknowledgment within the required time … no deduction is allowed.”
The IRS stressed that “taxpayers may not cure the defect after the fact and receive a whole or partial deduction.” The effect of a failure to comply with the substantiation requirements “is total denial of deduction; partial deduction is foreclosed by statute.” IRS Letter Ruling 200848076.
