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Finally, petitioner himself reported the value of the
additional 25 shares of SWI stock he purchased on April
4, 1990, at $2,600 per share. Taking into account
changes in general economic and other circumstances
between June 30, 1989, and the dates of these subsequent
valuations, we find respondent's valuation much more
reasonable than petitioners'.
In light of the foregoing, we reject petitioners'
expert's valuation in its entirety. Cf. Buffalo Tool
& Die Manufacturing Co. v. Commissioner, 74 T.C. 441, 452
(1980); see also Neely v. Commissioner, 85 T.C. 934, 944
(1985). Accordingly, we find that petitioners have failed
to satisfy their burden of proving that respondent's
determination of the fair market value of the subject
stock is erroneous. See Rule 142(a). We thus accept
respondent's determination in its entirety and find that
the stock purchased by petitioner had a fair market value
of $1,739.82 per share as of June 30, 1989.
Next, we must decide whether petitioners are liable
for the accuracy-related penalty prescribed by section
6662. Respondent determined that petitioners are liable
for the penalty with regard to the deficiencies
attributable to both the SWI stock and an unrelated
transaction involving stock in Home Depot, Inc. Although
the amount of the deficiency arising from the transaction
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