- 12 - 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 adequatePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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