- 15 - 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011