Wayne M. and Janet L. Johnson - Page 11

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          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                    
               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.                                                             

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