Two Tax Court decisions, including two from May 2012, demonstrate the concerns that arise both when the charitable contributions substantiation rules are strictly applied and when they are not. In order to address problems of valuation, the U.S. Congress has addressed the charitable substantiation rules five times in the past 30 years. Each time, Congress has strengthened the rules to try to prevent overvaluation, but the rules have not proved satisfactory. This brief suggests reasonable and fair reforms to substantiation rules.