Allen M. Glick - Page 27

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          Special Use Permit will have no effect on the valuation of the              
          Property.                                                                   
               Based upon an analysis of all the valuation evidence                   
          introduced through both testimony and documentation, and giving             
          due consideration to the credibility of the witnesses at trial,             
          we determine that the fair market value of the Property at the              
          time of the contribution was $10,970,000.22                                 

                      Additions to Tax, Penalties, and Interest                       

          Sections 6653(a) and 6662 Additions and Penalty for Negligence or           
          Intentional Disregard of Rules and Regulations                              

               Respondent also determined that petitioner was liable for              
          additions to tax and a penalty for negligence or intentional                
          disregard of rules or regulations (1) under section 6653(a),                
          equal to 5 percent of the respective underpayments for 1987 and             
          1988, and (2) under section 6662, equal to 20 percent of a                  
          portion of the underpayment for 1989.  Respondent determined that           
          the 20-percent addition under section 6662 should apply with                
          respect to the entire underpayment for 1989.  Respondent further            
          determined that petitioner was liable for an addition to tax                


               22Our determination is also supported by the previous offer            
          made by Eastleigh Development to purchase the Property for $10              
          million plus 20 percent of the profit from the development of the           
          Property.                                                                   
               See the appendix for calculation of our valuation                      
          determination.                                                              




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