Recent Tax Court cases have demonstrated the Internal Revenue Service’s (IRS) increase in strict compliance with the substantiation requirements for charitable donations. For example, a $64.5 million charitable contribution was recently disallowed because there was no written acknowledgment from the recipient at the time the return was filed. After the donation was made and prior to the return filing, the charity sent the taxpayer a letter acknowledging receipt of a donated facade easement. Unfortunately, this letter did not state whether the charity had provided any goods or services to the taxpayer, or whether the charity had otherwise given the taxpayer anything of value, in exchange for the easement. The taxpayer did include a copy of the appraisal report for the amount of the donation, a copy of the charity’s letter, and Form 8283, Noncash Charitable Contributions, executed by the appraiser and by a representative of the charity with the return. The only item missing was the statement “No goods or services were provided in exchange for your donation” in the acknowledgment letter. (15 West 17th Street LLC v. Commissioner, 147 T.C. No 19, December 22, 2016). These eleven missing words caused the disallowance of the $64.5 million contribution. Only $5.8 million per missing word.