Jerry L. and Valerie J. Hill - Page 5

          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                   
          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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