- 19 - 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 ofPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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