Stanley Joseph Jennings - Page 12




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               Petitioner testified that he believes he has contributed               
          more than $40,000 since 1977.  The only specific gift that he               
          identified is the speaker for the organ he donated to the church.           
          Petitioner had a receipt for the speaker that he bought on                  
          November 30, 1989.  However, the receipt does not show that he              
          contributed it or, if he did, when he contributed it.  He did not           
          identify any other specific gifts, donees, dates, or amounts, or            
          offer any other evidence substantiating his charitable                      
          contributions before 1994.                                                  
               Petitioner did not show that any amounts qualified as                  
          charitable contributions in prior years, or that any excess                 
          charitable contributions existed from prior years that were                 
          available to be carried over to 1994, 1995, and 1996.  See sec.             
          170(d).  We conclude that petitioner may not deduct any                     
          charitable contributions carried over from prior years.                     
               4.   Conclusion                                                        
               We conclude that petitioner may not deduct any amount as               
          charitable contributions for 1994, 1995, or 1996, or excess                 
          charitable contributions carried over to 1994, 1995, or 1996.               
          B.   Accuracy-Related Penalties for Negligence and Substantial              
               Understatement of Tax                                                  
               Petitioner contends that he was not negligent because he               
          sought advice from Bunten.  We disagree.  Bunten told petitioner            
          that he was required to substantiate charitable deductions.                 
          Petitioner deducted the amounts without having adequate                     





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