Estate of Ronald Busch, Deceased, Rochelle Busch, Executrix and Rochelle Busch, et al. - Page 58

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          advice as to whether payments were properly deductible or                   
          capitalized.  The advice relied upon by the taxpayer in Mauerman            
          was within the scope of the advisers' expertise, the                        
          interpretation of the tax laws as applied to undisputed facts.              
          In Snyder's cases, particularly with respect to valuation, he               
          relied upon advice which was outside the scope of expertise and             
          experience of his supposed advisers.  Consequently, we consider             
          Snyder's reliance on the Mauerman case inapplicable.                        
               Snyder also submitted into evidence preliminary reports                
          prepared for respondent by Ernest D. Carmagnola (Carmagnola), the           
          president of Professional Plastic Associates, in support of his             
          position that the valuation he claimed on his returns was                   
          reasonable.  Carmagnola had been retained by the IRS in 1984 to             
          evaluate the Sentinel EPE and EPS recyclers in light of what he             
          described as "the fantastic values placed on the [recyclers] by             
          the owners."  Based on limited information available to him at              
          that time, Carmagnola preliminarily estimated that the value of             
          the Sentinel EPE recycler was $250,000.  However, after                     
          additional information became available to him, Carmagnola                  
          concluded in a signed affidavit, dated March 16, 1993, that the             
          machines actually had a fair market value of not more than                  
          $50,000 each in the fall of 1981 and 1982.                                  
               We accord no weight to the Carmagnola reports submitted by             
          petitioners.  The projected valuations therein were based on                






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