Christiana Stamoulis - Page 13

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          preparation of a tax return.”  Sec. 1.6662-3(b)(1), Income Tax              
          Regs.; see sec. 6662(c).  Furthermore, “any failure by the                  
          taxpayer to keep adequate books and records or to substantiate              
          items properly” also constitutes “negligence”.  Sec. 1.6662-                
          3(b)(1), Income Tax Regs.  The section 6662(a) accuracy-related             
          penalty does not apply if the taxpayer demonstrates that there              
          was a reasonable cause for the underpayment and that the taxpayer           
          acted in good faith with regard to the underpayment.  Sec.                  
          6664(c)(1); sec. 1.6664-4(a), Income Tax Regs.  The applicability           
          of this exception is made on a case-by-case basis and depends               
          upon all of the pertinent facts and circumstances, such as                  
          whether the taxpayer made efforts to assess his proper tax                  
          liability and whether there was an honest misunderstanding of               
          fact or law that is reasonable in light of the experience,                  
          knowledge, and education of the taxpayer.  Higbee v.                        
          Commissioner, 116 T.C. 438, 448 (2001); sec. 1.6664-4(b)(1),                
          Income Tax Regs.                                                            
               The charitable contribution deduction claimed on                       
          petitioner’s return consists of the following three components:             
          (1) Cash donations, (2) donations of property, and (3) a                    
          carryover from a prior year.  Petitioner failed to produce                  
          sufficient substantiating evidence to support the amount claimed            
          for cash contributions and produced nothing with respect to the             

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