Martin H. Droz - Page 18

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          the Mark IV helmet at issue to the museum, petitioner offered to            
          sell that helmet to Dr. Jamieson and to Mr. Gilliam for $10,000.            
          Both Dr. Jamieson and Mr. Gilliam informed petitioner that the              
          helmet that he was offering for sale was a Mark IV helmet, and              
          not a space helmet, and that it was worth approximately $300 to             
          $500.  Petitioner's offer to sell the Mark IV helmet at issue for           
          $10,000 indicates that he was aware that a value of $76,700 for             
          that helmet was grossly overstated.  In addition, he was aware              
          that, at least as far as Dr. Jamieson and Mr. Gilliam were                  
          concerned, a value of $76,700 for the helmet at issue was very              
          substantially overstated.  Based on our review of the present               
          record, we find that petitioner has failed to establish that his            
          reliance on the advice of Mr. Hetz was reasonable or that he                
          acted in good faith.  See Van Zelst v. Commissioner, T.C. Memo.             
          1995-396; Harding v. Commissioner, T.C. Memo. 1995-216.                     
               On the record before us, we find that petitioner has not               
          established that he acted with reasonable cause and in good faith           
          in placing a value of $76,700 on the Mark IV helmet at issue.  We           
          therefore sustain respondent's determination for 1991 imposing              
          the accuracy-related penalty on petitioner.                                 
               To reflect the foregoing and the concessions of the parties,           
                                             Decision will be entered                 
                                        under Rule 155.                               







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