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unique position to determine for which expenses CPSG, Inc.
reimbursed them. The balance are those deductions which
respondent denied. Incomplete copies of credit card statements
and petitioner’s self-serving testimony are not sufficient to
substantiate the deductions claimed. Accordingly, petitioners
have failed to demonstrate that they were not negligent in
claiming these disallowed deductions. Xuncax v. Commissioner,
T.C. Memo. 2001-226; see sec. 1.6662-3(b)(1), Income Tax Regs.
Lastly, we turn to whether a penalty is appropriate due to
the double charitable contribution deduction claimed by
petitioners on their 1996 return. The evidence demonstrates that
petitioners made a mistake in preparing their 1996 return. On
brief, petitioners argued that, relying upon Rev. Proc. 96-58,
1996-2 C.B. 390, they had made adequate disclosure of the
charitable contribution deduction by completing the charitable
contribution portion of Schedule A, Itemized Deductions. Rev.
Proc. 96-58, supra, provides that additional disclosure of facts
is not necessary to fall within the auspices of section
6662(d)(2)(B), which allows for the reduction in the amount of
the understatement, provided that the forms and attachments are
completed in a clear manner and in accordance with their
instructions. Rev. Proc. 96-58, sec. 4.01, supra. Although Rev.
Proc. 96-58 is applicable to whether a taxpayer has disclosed
sufficient facts to be entitled to reduce the amount of the
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