David Russell Jacobson - Page 4

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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                    
               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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