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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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