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report for those three categories of memorabilia only. We find
that the total fair market value of the collection in December
1985 was $50,412.
4. Additions to Tax for Valuation Overstatement
Section 6659(a) imposes an addition to tax if there is an
underpayment of tax of at least $1,000, sec. 6659(d),
attributable to an overstatement of the value of charitable
deduction property. This addition to tax is applied to each year
in issue, in this case all the years in which an underpayment
results from a deduction claimed pursuant to a charitable
contribution and its related carryover when such deductions are
“attributable to a valuation overstatement”. Sec. 6659(a); Todd
v. Commissioner, 862 F.2d 540, 542-543 (5th Cir. 1988), affg. on
this issue 89 T.C. 912 (1987); see also Rogers v. Commissioner,
T.C. Memo. 1990-619. There is a valuation overstatement where
the claimed value is 150 percent or more of the amount determined
to be correct. Sec. 6659(c). Here, petitioners claimed a
charitable donation of $185,085. We have found the fair market
value of the collection to be $50,412. These figures place
petitioners' overstatement well in excess of the section 6659(c)
150 percent threshold.
Petitioners seek relief under section 6659(e), which allows
waiver of “all or any part of the addition to the tax provided by
this section on a showing by the taxpayer that there was a
reasonable basis for the valuation * * * and that such claim was
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