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the Cohan rule ($300) would result in total itemized deductions
for 2000 that are less than the standard deduction applicable to
a head of household that respondent has allowed to petitioner in
computing her deficiency for that year. Therefore, because of
our disallowances with respect to petitioner’s claimed deductions
for cash and (other) noncash contributions for 2000, the issue of
whether we may allow her a deduction, under the Cohan rule, for
noncash contributions to L.A. Family Housing is moot.
C. Section 6662(a) Penalty
Section 6662(a) imposes a penalty equal to 20 percent of the
underpayment in tax attributable to, among other things,
negligence or disregard of rules or regulations (without
distinction, negligence). See sec. 6662(b)(1). The penalty for
negligence will not apply to an underpayment of tax to the extent
the taxpayer can show both reasonable cause and that the taxpayer
acted in good faith. See sec. 6664(c)(1). Negligence “includes
any failure by the taxpayer * * * to substantiate items
properly.” Sec. 1.6662-3(b)(1), Income Tax Regs.
All of the charitable contributions deductions that we have
disallowed herein are attributable to a lack of adequate
substantiation, including the deductions disallowed because the
acknowledgments obtained by petitioner from donees were in
violation of section 170(f)(8). Petitioner’s failure to obtain
acknowledgments stating that the donee did not provide goods or
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