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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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