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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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