Daniel L. and Ingrid N. Carroll - Page 31




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          making further inquiry and intentionally disregarded rules and              
          regulations.                                                                
               In view of his sophistication and educational background,              
          petitioner should have been able to determine that the Sentinel             
          EPE recyclers were not unique, that they were not worth the                 
          amount ascribed to them, and that Clearwater lacked economic                
          substance and had no potential for profit.  Taking all of the               
          above factors into consideration, we think it is more likely than           
          not that petitioners invested in Clearwater in an effort to                 
          generate tax benefits, rather than to make a profit.  Therefore,            
          under the circumstances of this case, petitioners failed to                 
          exercise due care in claiming loss deductions and tax credits               
          with respect to Clearwater.                                                 
               Upon consideration of the entire record, we hold that                  
          petitioners are liable for the additions to tax for negligence              
          under section 6653(a)(1) and (2).  Respondent is sustained on               
          this issue.                                                                 
          Issue 3.  Section 6659 Valuation Overstatement                              
               Petitioners also contest the addition to tax for valuation             
          overstatement under section 6659.                                           
               A value claimed on a return that exceeds the correct value             
          by 150 percent or more constitutes a valuation overstatement.               
          See sec. 6659(c).  The Sentinel EPE recyclers were valued at                







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