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* * *
(iii) In the absence of a canceled check or receipt
from the donee charitable organization, other reliable
written records showing the name of the donee, the date
of the contribution, and the amount of the contribution.
Petitioner provided no written evidence of her contributions. We,
therefore, sustain respondent's determination disallowing
petitioner's charitable deductions.
Addition to Tax - Accuracy Related Penalty
The final issue for decision is whether petitioner is liable
for the accuracy-related penalty for negligence or substantial
understatement of income tax under section 6662(a). Section 6662
imposes an addition to tax equal to 20 percent of the portion of
the underpayment that is attributable to (1) negligence or
disregard of rules or regulations, or (2) substantial
understatement of income tax. Sec. 6662(a), (b)(1), (2).
The term "negligence" includes any failure to make a
reasonable attempt to comply with the provisions of the Internal
Revenue Code, and the term "disregard" includes any careless,
reckless, or intentional disregard. Sec. 6662(c). Negligence is
defined as the lack of due care or the failure to do what a
reasonable and ordinarily prudent person would do under the
circumstances. McGee v. Commissioner, 979 F.2d 66, 71 (5th Cir.
1992), affg. T.C. Memo. 1991-510; Marcello v. Commissioner, 380
F.2d 499, 506-507 (5th Cir. 1967), affg. in part and remanding in
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