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have received 81 times that amount to make a profit on their
investment.
The fact that Dollar leased petitioners an interest
purportedly worth $93,750 for $4,850, which immediately generated
tax savings of $9,629.10, should have prompted petitioners to
look beyond Dollar for advice. See Allen v. Commissioner, supra
at 353 (taxpayer negligent where tax savings were almost double
the amount of their cash outlay).
We hold that petitioners are liable for the additions to tax
under section 6653(a) for 1980, 1981, 1982, and 1983.
3. Whether Petitioners Overvalued the Video Games
Respondent determined that petitioners are liable for
additions to tax for valuation overstatement under section 6659.
That section provides for an addition to tax of up to 30 percent
of the underpayment of tax (of at least $1,000) attributable to a
valuation overstatement. Sec. 6659(a) and (b). A valuation
overstatement occurs where the claimed value or adjusted basis
of property is 150 percent or more of the value or adjusted basis
that is "determined to be the correct amount." Sec. 6659(c).
The Secretary may waive this addition to tax if the taxpayer
shows that there was a reasonable basis for the valuation
claimed, and that the claim was made in good faith. Sec.
6659(e). The Court reviews this determination for abuse of
discretion. Krause v. Commissioner, 99 T.C. 132, 179 (1992).
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