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Petitioner contends that he made charitable gifts of cash,
property, and articles to be published. Following concessions,1
the issues for decision are:
1. Whether petitioner is entitled to deduct charitable
contributions of $36,960.30 for 1994, $25,028.40 for 1995, and
$32,522.32 for 1996, as he contends, zero as respondent contends,
or some other amount. We hold that he may not deduct any
charitable contributions for the years in issue.
2. Whether petitioner is liable for the accuracy-related
penalties under section 6662(a). We hold that he is.
Section references are to the Internal Revenue Code in
effect during the years in issue. Rule references are to the Tax
Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioner lived in Lima, Ohio, when the petition was filed. He
worked for the Ford Motor Co. in the years in issue.
1 Petitioner concedes that he may not deduct amounts that
he paid for a banquet for his parents, gasoline, dental care,
lawn care, household repairs, and maintenance. In the notice of
deficiency, respondent disallowed petitioner’s $2,000 IRA
contribution for 1996. Petitioner offered no evidence and makes
no argument on this issue. Thus, petitioner has conceded this
issue. See, e.g., Bradley v. Commissioner, 100 T.C. 367, 370
(1993); Sundstrand Corp. v. Commissioner, 96 T.C. 226, 344
(1991); Rybak v. Commissioner, 91 T.C. 524, 566 n.19 (1988);
Money v. Commissioner, 89 T.C. 46, 48 (1987); Leahy v.
Commissioner, 87 T.C. 56, 73-74 (1986).
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