- 26 - By adding subparagraph (B) to section 6664(c)(2), Congress obviously intended that the taxpayer take some further steps beyond merely obtaining an appraisal from a qualified appraiser. We believe that petitioners’ actions in this case fall short of what subparagraph (B) requires. Petitioner had experience in real estate, given his activity in purchasing property at tax sales and reselling it, and successfully ran his own engineering and survey business. Thus he is chargeable with some sophistication in real estate matters. Taking into account petitioner’s experience, and the fact that he did not even visit the property until approximately 1 month before trial, we conclude that he failed to make a “good faith investigation” of the value of the contributed property within the meaning of section 6664(c)(2)(B) before claiming the value on the tax return. See Sergeant v. Commissioner, T.C. Memo. 1998-265. Therefore, petitioners have failed to satisfy section 6664(c)(2)(B), and the reasonable cause exception does not apply. Accordingly, petitioners are liable for the accuracy-related penalty under section 6662(h) for 1990 and 1992 as determined by respondent. An appropriate order will be issued.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26
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