William Joel Ashley - Page 15




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          cash or check, the regulations require the taxpayer to maintain             
          specific records.  See sec. 1.170A-13(a), Income Tax Regs.                  
          Petitioner did not produce any evidence, beyond his vague and               
          incomplete testimony, to substantiate the $450 claimed                      
          contributions of money.11  Accordingly, he has failed to                    
          substantiate the deduction for charitable contributions as                  
          required by the Treasury regulations.                                       
          III. Section 6651(a) and Section 6654(a) Additions to Tax                   
               Section 6651(a) imposes an addition to tax for a taxpayer’s            
          failure to file a required return on or before the specified                
          filing date, including extensions.  The addition to tax is                  
          inapplicable, however, if the taxpayer shows that the failure to            
          file the return was due to reasonable cause and not to willful              
          neglect.  See sec. 6651(a)(1).                                              
               Petitioner argues that respondent erred in imposing the                
          section 6651(a) addition to tax because petitioner timely filed             
          his return.  Because the record does not support petitioner’s               
          contention, we conclude that the addition to tax is warranted if            
          the Rule 155 computations show that petitioner has an                       
          underpayment of tax.                                                        
               On brief, petitioner does not specifically address the                 
          section 6654 addition to tax for a taxpayer’s failure to make               
          estimated tax payments other than stating that he does not have a           

               11  We need not accept a taxpayer’s self-serving and                   
          uncorroborated testimony.  See Wood v. Commissioner, 338 F.2d               
          602, 605 (9th Cir. 1964), affg. 41 T.C. 593 (1964); Tokarski v.             
          Commissioner, 87 T.C. 74, 77 (1986).                                        





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