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T.C. 342, 348-349 (1989), affd. 898 F.2d 50 (5th Cir. 1990); Deel
v. Commissioner, T.C. Memo. 1990-545.
In the instant case, after the last day prescribed for
filing a return for 1981, petitioners filed an amended return for
that year which is an admission of an underpayment of tax of
$11,744. See sec. 301.6653-1(c)(1), Proced. & Admin. Regs. We
note that respondent's transcripts also reflect this same amount.
Accordingly, we find that the amount of the underpayment
attributable to negligence under section 6653 for 1981 is
$11,744. Petitioners did not make any arguments with respect to
1984 regarding the amount of any underpayment attributable to
negligence under section 6653. Therefore, we sustain
respondent's determination on this point for 1984.
The next issue is whether petitioners are liable for the
additions to tax under section 6659 for a valuation
overstatement. Section 6659 imposes a graduated addition to tax
wherever an individual has an underpayment of tax which equals or
exceeds $1,000 and which is attributable to a valuation
overstatement. The amount "attributable to" a valuation
overstatement is equal to the difference between a taxpayer's
correct tax liability and the tax liability as reduced by the
valuation overstatement. A valuation overstatement occurs when
the value of any property or the adjusted basis of any property,
claimed on any return is 150 percent or more of the amount
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