Kenneth and Dorothy Hitchen - Page 16

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          sustain respondent’s determinations regarding the substantial               
          valuation overstatements and the gross valuation misstatement.              
          Petitioners have not argued, and no evidence in the record                  
          suggests, that they had a reasonable basis or reasonable cause              
          for making the claims.  Accordingly, with respect to 1984 and               
          1985--the years in which the entire deficiency was based upon               
          disallowance of the general business credit carrybacks–we hold              
          that petitioners are liable for the section 6659(a) addition to             
          tax with respect to the entire amount of the deficiency in each             
          year.  We further hold that petitioners are liable for the                  
          section 6659(a) addition to tax in 1987 and 1988, and the 40                
          percent section 6662(a) penalty in 1989, with respect to that               
          portion of the deficiency in each of those years that is                    
          attributable to respondent’s disallowance of the Schedule F                 
          depreciation deductions.  Petitioners, however, are not liable              
          for the respective additions to tax with respect to the remaining           
          portions of the deficiencies in 1987, 1988, and 1989, because               
          these portions were not attributable to valuation overstatements.           
               Finally, we note that in the notice of deficiency,                     
          respondent determined that petitioners are liable for the section           
          6662(a) penalty in 1989 both for a substantial valuation                    
          overstatement and a gross valuation misstatement, resulting in              
          two separate additions to tax.  However, the penalty for a gross            
          valuation misstatement is applied in lieu of the penalty for a              






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