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position regarding self-employment taxes in 1997 and 1999, we
conclude that they were not negligent regarding this item in
2000. Their position regarding income tax liability for this
amount, by contrast, lacks any basis. Likewise, petitioners'
failure to substantiate the claimed expenses in 2000 for Native
American Finance, and their commingling of unrelated expenses in
that claim, disregards their record-keeping obligations. See
sec. 6001; sec. 1.6001-1(a), Income Tax Regs. The foregoing
regulations were also disregarded when petitioners claimed
casualty losses that were more than $3,000 greater than what they
could substantiate. Their failure to substantiate nearly $4,000
in claimed charitable contribution deductions for 2000 disregards
the specific requirements of section 170(f)(8) and/or section
1.170A-13(a)(1), Income Tax Regs. Their failure to report
taxable interest income in 2000 is unexplained. We accordingly
conclude that petitioners' underpayment for 2000, with the
exception of the portion noted above, is attributable to
negligence or disregard of rules or regulations.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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