- 27 - 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.Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
Last modified: May 25, 2011