Robert and Karen O'Connor - Page 27




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          the record for continually incurring these unabated expenditures.           
          We also note that petitioners maintained their residence on the             
          ranch property and it was the situs for future charitable                   
          activity, to commence a few years after the years under                     
          consideration.                                                              
               Respondent also argues that petitioners claimed large                  
          overvalued deductions for contributions of property to CBR in               
          1990 and 1991.  In addition, respondent contends that petitioners           
          failed to furnish a qualified appraisal identifying the values of           
          items contributed to CBR as required by the regulations.  We have           
          already held that petitioners’ property valuations are                      
          substantially overstated and that contributions of labor to CBR             
          are deductible in greatly reduced amounts.                                  
               Petitioners argue that any underpayment was reasonable                 
          because they acted in good faith and they relied on the advice of           
          a certified public accountant to whom they provided complete and            
          accurate records.  The evidence does not bear out petitioners’              
          argument.  Instead, the record reflects that petitioners failed             
          to follow the advice of their accountant with regard to achieving           
          profitability in their farm operation.  They have not established           
          that they acted in good faith.  In addition, petitioners failed             
          to provide adequate records to support their claimed deductions             
          for contributions to CBR.  Thus, petitioners have not shown that            
          their actions were reasonable or that they attempted to comply              






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