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total amounts listed in the respective donation ledgers. The
record does not establish the reason for this difference.
We also find petitioner not credible. We are troubled by
petitioner's testimony that although he was Agape's president and
one of its incorporators, he had no knowledge of how much Agape
paid Reverend McWilliams for his services, nor did he know
whether or not Ms. Spiegel always deposited the contributions
into the TFC account. Moreover, petitioner could not explain
where the money went after petitioners gave it to Ms. Spiegel.
Petitioner also had difficulty explaining why the payee lines
were left blank.
On the basis of this record, we find that petitioners failed
to establish that the amounts of the purported charitable
contributions at issue were to or for the use of Agape within the
meaning of section 170(c). Accordingly, respondent is sustained
on this issue.
Finally, we must decide whether petitioners are liable for
accuracy-related penalties in the amounts of $309 and $359 for
1991 and 1992, respectively. Section 6662(a) imposes an
accuracy-related penalty in the amount of 20 percent of the
portion of an underpayment of tax attributable to negligence or
disregard of rules or regulations. Sec. 6662(a) and (b)(1).
Negligence is any failure to make a reasonable attempt to comply
with the provisions of the Internal Revenue laws. Sec. 6662(c);
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