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Combined Federal Campaign (CFC) amounts and "clothing donations
at local churches". The Court thinks that documentation of
petitioners' CFC donations would be readily available. The sheet
does not indicate the "local churches" to which the clothing
contributions were made. There is no discernable relationship
between the sum of the items listed on the sheet and the total
charitable deductions claimed on the return for 1995. The sheet
does nothing to support petitioners' claims. The Court is not
convinced from the record that petitioners made the charitable
contributions claimed for 1995.
Respondent’s determination that petitioners are not entitled
to deductions for 1995 for charitable contributions is upheld.
Petitioners offered no evidence with respect to whether part
of their underpayment of tax for the years 1995 and 1996 was due
to negligence or to disregard of rules or regulations. The Court
holds therefore that petitioners are liable for the accuracy-
related penalty under section 6662 for both 1995 and 1996.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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Last modified: May 25, 2011