The Pennsylvania Commonwealth Court has refused to grant real estate tax exemption to another Section 202 housing for the elderly project.  The result is not surprising.  The case is interesting because of the grasping-at-straws arguments the taxpayer made to try to come within the state requirement to “donate or render gratuitously a substantial part of its services.”

A receipt for charitable contributions that includes an amount written in by the donor and not the charitable recipient does not satisfy the substantiation requirements to justify a charitable contribution deduction, the Tax Court has held recently.  It has denied claimed deductions of about $8800 for contributions allegedly made to the Islamic Society of East Bay-San Francisco in 2007 and 2008.

The Court has also denied deductions for various claimed business expenses and imposed additional penalty taxes.

The John S. and James L. Knight Foundation made a $3 million grant to the Collins Center for Public Policy in Florida in 2001, with $1.5 million designated for the purchase of real estate by an independent “land trust.”  The land trust was established and purchased the property to benefit the Overtown community.