Jane Crocker, F.K.A. Jane C. Jacobs, et al. - Page 18

                                       - 107 -                                        
          Indicated Value                                   $1,083,568                
          Rounded                                           $1,100,000                
               C.  Value Conclusion                                                   
               Based upon an analysis of all the valuation evidence                   
          introduced through both testimony and documentation, and giving             
          due consideration to the credibility of the witnesses at trial,             
          we hold that the fair market value of the Redwood City Fox as of            
          December 31, 1986, the date of its donation to the Players, was             
          $3,100,000.51                                                               
          III.  Addition to Tax and Penalties                                         
               The final issue is whether Jacobs is liable for an addition            
          to tax for negligence or disregard of rules or regulations under            
          section 6653(a)(1) for taxable year 1988; and whether Jacobs is             
          liable for accuracy-related penalties under section 6662 for                
          negligence or disregard of rules or regulations, any substantial            
          understatement of income tax, and/or any substantial valuation              
          overstatement for taxable years 1989 and 1990.                              
               A.  Addition to Tax for Negligence                                     
               For 1988, section 6653(a)(1) imposes an addition to tax                
          equal to 5 percent of the underpayment if any part of the                   
          underpayment is attributable to negligence or disregard of rules            
          or regulations.  "Negligence" means any failure to make a                   
          reasonable attempt to comply with the Internal Revenue Code, and            

               51 Respondent introduced evidence of the Redwood City Fox's            
          assessed value for purposes of California real property taxes.              
          We considered the property's 1986 assessed value for real estate            
          tax purposes, but we find that value not to represent the Redwood           
          City Fox's fair market value.                                               


Page:  Previous  90  91  92  93  94  95  96  97  98  99  100  101  102  103  104  105  106  107  108  109  Next

Last modified: May 25, 2011