- 31 -
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,
Page: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 NextLast modified: May 25, 2011