Bevel M. and Patricia N. Hoffpauir - Page 13

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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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