- 27 - 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 complyPage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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