- 8 - 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);Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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