- 325 - Under section 6662(g),96 respondent apparently takes the position that the determination whether the percentage threshold for a substantial or gross valuation understatement has been reached is made on a property-by-property basis. See Part XX Penalties Handbook, Internal Revenue Manual (RIA), sec. 120.1.5.11.2. In the absence of any argument to the contrary by any of the parties in this case, we use this specifically targeted approach. 96SEC 6662(g). SUBSTANTIAL ESTATE OR GIFT TAX VALUATION UNDERSTATEMENT. (1) In General.--For purposes of this section, there is a substantial estate or gift tax valuation understatement if the value of any property claimed on any return of tax imposed by subtitle B is 50 percent or less of the amount determined to be the correct amount of such valuation. * * * * * * * (h) INCREASE IN PENALTY IN CASE OF GROSS VALUATION MISSTATEMENTS. (1) In General.--To the extent that a portion of the underpayment to which this section applies is attributable to one or more gross valuation misstatements, subsection (a) shall be applied with respect to such portion by substituting “40 percent” for “20 percent”. (2) Gross Valuation Misstatements.--The term “gross valuation misstatements” means-- * * * * * * * (C) any substantial estate or gift tax valuation understatement as determined under subsection (g) by substituting “25 percent” for “50 percent”.Page: Previous 315 316 317 318 319 320 321 322 323 324 325 326 327 328 329 330 331 332 333 334 Next
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