Nathan P. and Geraldine V. Morton - Page 37

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             stock.  Petitioners argue that through these discussions,                
             petitioner made a reasonable effort to determine the                     
             value of SWI, and that he had no reason to expect that                   
             the stock was worth more than the $60.98 per share that                  
             he paid.  Petitioners also argue that given petitioner's                 
             business experience and expertise, this determination was                
             reasonable.  We disagree.                                                
                  Although petitioner is a successful businessman,                    
             he is neither an accountant nor an expert in property                    
             valuation.  The record indicates that petitioners                        
             received professional assistance in preparing their tax                  
             return for the year in issue.  However, there is nothing                 
             in the record to show that petitioners relied on expert                  
             advice in valuing the SWI stock, or that they provided                   
             the return preparer with all of the information needed to                
             value the stock.  Under the circumstances, we find that                  
             petitioners failed to do what a reasonable and ordinarily                
             prudent person would have done under the circumstances to                
             value the SWI stock.  See generally Neely v. Commis-                     
             sioner, 85 T.C. 934, 947 (1985).  Accordingly, we find                   
             that petitioners are liable for the penalty prescribed by                
             section 6662 for negligence with respect to the SWI                      
             stock.  Sec. 6662(b)(1).  It is unnecessary to consider                  
             whether they are liable for the same penalty by reason of                






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