- 31 - respondent's experts. However, we think that petitioner's attempt to discredit Grossman's and Lindstrom's findings was unpersuasive. To the contrary, we found both Grossman and Lindstrom to be qualified, impressive, and credible experts, and we rely heavily on their reports and testimony in making our finding of fact regarding valuation. We have found as an ultimate fact that the Sentinel EPS recyclers purchased by petitioner in 1982 did not have a fair market value at that time in excess of $50,000 per machine. The purchase price of $1,750,000 per machine is therefore inflated by 35 times its actual value. Having so found, it follows that the adjusted basis of the Sentinel EPS recycler claimed by petitioner on his returns is by definition overstated within the meaning of section 6662(e). In summary, petitioner overstated the value of his Sentinel EPE and EPS recyclers within the meaning of section 6662(e). Further, petitioner failed to present any persuasive evidence, nor are we able to conclude independently that petitioner acted with reasonable cause and good faith in valuing his recyclers. Thus, petitioner is liable for the accuracy-related penalty for 1989. C. Substantial Understatement of Income Tax Respondent also determined that petitioner was liable for the accuracy-related penalty for 1989 because he substantiallyPage: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
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