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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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