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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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