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cash and describe other property contributed, indicate whether
the donee organization provided any goods or services in
consideration for the contribution, and provide a description and
good faith estimate of the value of any goods or services
provided by the donee organization. Sec. 170(f)(8)(B); sec.
1.170A-13(f)(2), Income Tax Regs. Given that petitioners do not
have such a written acknowledgment from any of the recipients of
the disputed amounts, and have not established any exception to
this written acknowledgment requirement, see, e.g., sec.
170(f)(8)(D), we conclude that petitioners are precluded by the
statute from deducting the disputed amounts as charitable
contributions.
2. Accuracy-Related Penalty
Respondent also determined that petitioners are liable for
the accuracy-related penalty under section 6662(a). In relevant
part, section 6662(a) and (b) imposes an accuracy-related penalty
if any portion of an underpayment is attributable to negligence
or a substantial understatement of income tax. Negligence
includes any failure to make a reasonable attempt to comply with
the provisions of the internal revenue laws, any failure to keep
adequate books and records, and any failure to substantiate items
properly. Sec. 1.6662-3(b), Income Tax Regs. An understatement
of income tax is substantial if it exceeds 10 percent of the tax
required to be shown on the return or $5,000. Sec. 6662(d)(1).
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