Robert Gottsegen - Page 31

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          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 substantially              






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