Jin Xiong - Page 18




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               Although petitioner did not present any documentary                    
          substantiation of his cash charitable contributions, he testified           
          that he had made such contributions to his local church.  We find           
          this part of petitioner’s testimony credible.  Therefore, the               
          claimed cash contributions totaling $200 are deductible.  The               
          claimed deduction for charitable contributions of property was              
          substantiated by receipts from a charitable organization and by             
          receipts showing the acquisition cost to petitioner of some                 
          donated property, such as a bicycle and artwork.  But petitioner            
          did not substantiate the date-of-donation value of the property             
          donated to charity.  We therefore sustain respondent’s                      
          determination that the date-of-donation value of the donated                
          property did not exceed $500.  Petitioner is therefore entitled             
          to a deduction for contributions of property only in the amount             
          of $500.                                                                    
               As noted supra, respondent determined a section 6662(a)                
          penalty for 2003.  Pursuant to section 6662(a) and (b)(1) and               
          (2), a taxpayer is liable for a penalty of 20 percent of the                
          portion of an underpayment of tax attributable to (1) negligence            
          or disregard of rules or regulations, or (2) any substantial                
          understatement of tax.  In addition, a taxpayer is liable for the           
          section 6662(a) penalty with respect to the portion of the                  
          underpayment of tax attributable to any substantial valuation               
          misstatement under chapter 1.  Sec. 6662(b)(3).                             







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