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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
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.
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