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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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