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of that report was approximately $76,700.
With respect to petitioner's reliance on the accountant who
prepared his 1991 return, petitioner did not call him as a
witness. Thus, the record is devoid of any evidence relating to
what information petitioner may have provided him or what advice
he might have given petitioner with regard to the value placed on
the helmet at issue for purposes of the charitable contribution
deduction at issue. Based on our review of the instant record,
we find that petitioner has failed to establish that his reliance
on the advice of the return preparer was reasonable or that he
acted in good faith.
With respect to petitioner's reliance on Mr. Hetz, petition-
er did not call him as a witness. Thus, the record is devoid of
any evidence relating to what information petitioner may have
provided to Mr. Hetz about the Mark IV helmet that Mr. Hetz was
asked to value. Nor does the record contain any reliable evi-
dence establishing, inter alia, (1) that Mr. Hetz was qualified
in appraising personal property of the type at issue, (2) that
the Mark IV helmet that was the subject of the Hetz report is the
Mark IV helmet at issue, (3) why Mr. Hetz employed the cost
approach in arriving at the fair market value of the Mark IV
helmet that was the subject of the Hetz report, or (4) why Mr.
Hetz did not consider the "Sale of [a] similar Helmet." We also
note that around 1990 or 1991, shortly before petitioner donated
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