- 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
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