The New York State Tax Appeals Tribunal has upheld the decision of an Administrative Law Judge that a claimed charitable deduction was properly denied as unsubstantiated, and that certain amounts either included in salary reported on a W-2 or reported as miscellaneous income on a federal Schedule C must be included in New York taxable income. Matter of Rabbi Milton Balkany and Sara Balkany, DTA No. 823424 (N.Y.S. Tax App. Trib., Oct. 28, 2015). Rabbi Balkany claimed to have paid amounts to vendors and other obligees of a religious school for which he worked, and argued that other amounts owed to him by a third party were similarly paid to creditors of the religious school for its benefit. The Tribunal denied the deductions in the absence of any documentation, such as canceled checks or receipts from the charitable organization, noting that IRC § 170(a) requires a contemporaneous written acknowledgment by the organization for any contribution of $250 or more, and that even under the “less stringent” recordkeeping requirements of Treas. Reg. § 1.170A-13(a)(1), the proffered records were “grossly incomplete,” and the ALJ had found the taxpayer’s testimony “‘completely unreliable.’”