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Salvation Army receipts on the original cost of the items.
Petitioner did not provide any evidence of the fair market value
of the property at the time of the alleged contributions.
Because petitioner assigned original cost values to all the items
rather than fair market value at the time the items were donated
as required by section 1.170A-1(c), Income Tax Regs., petitioner
has not established entitlement to a deduction for any of the
items listed on the AMVETS or Salvation Army receipts.
Respondent determined that petitioner is liable for
accuracy-related penalties under section 6662. Section 6662(a)
imposes a penalty in an amount equal to 20 percent of the portion
of the underpayment of tax attributable to one or more of the
items set forth in section 6662(b). Respondent asserts that the
underpayments in issue are due to petitioner's negligence or
disregard of rules or regulations. Sec. 6662(b)(1).
Negligence has been defined as the failure to do what a
reasonable and ordinarily prudent person would do under the
circumstances. Neely v. Commissioner, 85 T.C. 934, 947 (1985).
Respondent's determinations are presumed correct, and petitioner
bears the burden of proving otherwise. Rule 142(a); Luman v.
Commissioner, 79 T.C. 846, 860-861 (1982).
Petitioner was unable to provide substantiation for her
beginning and ending inventory values for her wholesale activity.
Further, petitioner was unable to provide substantiation for the
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