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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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