- 11 - testimony as to whether the contributions in issue were in fact made to Goodwill, what the donations specifically consisted of, and the value thereof. Although petitioner repeatedly asserted that respondent's Appeals Officer "did not give [him] a chance to submit Form 8283", petitioner did not submit Form 8283, or any other type of documentation, to substantiate the claimed deduction. Petitioner's uncorroborated, vague testimony does not satisfy the substantiation requirements of section 170(a)(1) and section 1.170A-13(b)(1), Income Tax Regs. Accordingly, we sustain respondent's determination on this issue. 3. Accuracy-Related Penalty The final issue for decision is whether petitioners are liable for the accuracy-related penalty pursuant to section 6662(a). Respondent determined petitioners were liable for the accuracy-related penalty under section 6662(a) for 1994. The accuracy-related penalty is equal to 20 percent of any portion of an underpayment of tax required to be shown on the return that is attributable to the taxpayer's negligence or disregard of the rules or regulations. See sec. 6662(a) and (b)(1). "Negligence" includes of any failure to make a reasonable attempt to comply with the provisions of the Internal Revenue Code. Sec. 6662(c). "Disregard" includes any careless, reckless, or intentional disregard. Id.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011