Pennel Phlander Irwin - Page 19

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            contributions to charitable organizations are deductible as                                   
            itemized deductions.  Secs. 170(a), 67(b)(4).  Petitioner claims                              
            that these expenses were incurred for the purpose of collecting                               
            research for his writing activities, thereby rendering the                                    
            expenses deductible under section 162.  Petitioner, however, has                              
            failed to specify the precise nature of the research materials he                             
            received in consideration for the payments in question.  As such,                             
            we regard the payments as charitable contributions under section                              
            170.  Petitioner did not elect to itemize deductions on his 1990                              
            return.  Therefore, he is not entitled to a charitable                                        
            contribution deduction.                                                                       
                  3.  Self-Employment Tax                                                                 
                  With regard to his writing activities, petitioner reported                              
            self-employment income in 1990 and 1992.  Respondent asserts that                             
            these amounts are subject to the self-employment tax imposed by                               
            section 1401.  Petitioner has the burden of proving that                                      
            respondent erroneously determined liability for the self-                                     
            employment tax.  Snyder v. Commissioner, T.C. Memo. 1995-285.                                 
            Petitioner has failed to address this issue.  As such, we sustain                             
            respondent's determination imposing the self-employment tax on                                
            the Schedule C income.                                                                        
                  4.  Accuracy-Related Penalty Under Section 6662(a)                                      
                  Respondent determined that petitioner is liable for the                                 
            accuracy-related penalty provided under section 6662(a).  The                                 
            accuracy-related penalty is equal to 20 percent of any portion of                             




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