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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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