Thomas E. and Joan A. Bennett - Page 31

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          Ingersoll-Rand *** all invested in this," while Bennett testified           
          that he was "very much influenced" by the actions of his fellow             
          executives and that the investment by people he respected "made a           
          considerable impact" on him.  However, in our view the record in            
          these cases, including the testimony of Black and Bennett and               
          their manner in presenting that testimony, establishes that they            
          are men of education, experience, and talent in the business of             
          manufacturing and selling machinery, that during the time in                
          issue they were senior executives of a large machinery                      
          manufacturing company, that they were highly knowledgeable about            
          appropriate pricing for a great variety of machinery, that they             
          had the ability and resources to learn the value of the machinery           
          involved in the Empire plastics recycling venture, in which they            
          invested, and that they could have obtained such information                
          without undue expense or effort.                                            
               Upon consideration of the entire records, we hold that                 
          petitioners are liable for the negligence additions to tax under            
          the provisions of section 6653(a)(1) and (2) for 1981.                      
          Respondent is sustained on this issue.                                      
          Issue 2.  Sec. 6659 Valuation Overstatement                                 
               In amendments to the answers, respondent asserted additions            
          to tax with respect to petitioners in these cases under section             
          6659 for valuation overstatement.  Because these additions were             
          raised for the first time in amendments to the answers,                     






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