- 46 -
On the instant record, we reject petitioners’ contention
that respondent’s determination under section 6662(a) is wrong
because “they correctly reported their gift”. We have found on
that record that petitioners are not entitled to the claimed
charitable contribution deduction.
On the instant record, we also reject petitioners’ conten-
tion that respondent’s determination under section 6662(a) is
wrong because they “had substantial authority for their return
position”. On that record, we find that all of the authorities
on which petitioners rely to support their position regarding the
claimed charitable contribution deduction are distinguishable
from the instant case and that their reliance on those authori-
ties is misplaced.
Based on our examination of the entire record before us, we
find that petitioners have failed to establish error in respon-
dent’s determination that they are liable for the year at issue
for the accuracy-related penalty under section 6662(a). Conse-
quently, we sustain that determination.
To reflect the foregoing and the concessions of petitioners,
Decision will be entered
for respondent.
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