- 37 - 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 ofPage: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 Next
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