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claimed. INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992).
Petitioner claimed at trial that he is entitled to deduct
for the year at issue money that he contends he contributed to
various charitable organizations during that year. In support of
that claim, petitioner relied on his general, conclusory, and
uncorrobrated testimony. We are unwilling to rely on that
testimony. In order to be deductible, contributions of money
must be substantiated by a canceled check, a receipt from the
donee, or other reliable written records. Higbee v. Commis-
sioner, 116 T.C. 438, 443 (2001); sec. 1.170A-13(a)(1), Income
Tax Regs. On the record before us, we find that petitioner has
failed to satisfy his burden of substantiating his claimed
charitable contributions during 1993.
We turn now to the determinations in the notice that peti-
tioner is liable for additions to tax under sections 6651(a)(1)
and 6654(a). With respect to section 6651(a)(1), petitioner
concedes that he did not file a tax return for the year at issue.
Assuming arguendo that respondent’s examination of the year at
issue began after July 22, 1998, we find that respondent has
satisfied respondent’s burden of production under section 7491(c)
with respect to respondent’s determination under section
6651(a)(1).
In support of his position that he is not liable for the
addition to tax under section 6651(a)(1), petitioner claimed at
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