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that demonstrates that these alleged donees were qualified
charitable organizations. Moreover, these donees are not listed
in IRS Publication 78, "Cumulative List of Organizations
Described in Section 170(c) of the Internal Revenue Code".
For the foregoing reasons, we hold that petitioner is not
entitled to a deduction for charitable contributions in an amount
greater than the amount determined by respondent.
5. Unreimbursed Employee Expenses and IRA Contribution Deductions
On his 1993 Federal income tax return, petitioner claimed a
deduction for unreimbursed employee expenses in the amount of
$5,700, and an IRA contribution deduction in the amount of
$2,000. Respondent has determined that petitioner failed to
substantiate the claimed IRA deduction and was entitled only to a
deduction for unreimbursed employee expenses in the amount of
$224. Petitioner has failed to present any documentation or
testimony to support his claimed deductions. Accordingly,
petitioner is not entitled to a deduction for unreimbursed
employee expenses in an amount greater than the amount determined
by respondent and is not entitled to a deduction for IRA
contributions.
6. Accuracy-Related Penalty
Section 6662(a) imposes a penalty of 20 percent of the
portion of the underpayment which is attributable to negligence
1(...continued)
property other than money on his 1993 Federal income tax return.
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