- 54 - to the appropriateness of the section 6662 penalty that even respondent’s expert made significant errors in his various calculations. Complicating the valuation presented to the parties and to the Court herein was the difficult question as to how the Internet and the risks and opportunities associated therewith should be regarded as affecting TPC. The evaluation in this case of such intangible risks and opportunities was difficult and imprecise. Certainly, the experts for the estate were aggressive in their relatively low valuation of TPC. Respondent’s expert was aggressive in his relatively high valuation of TPC. We note that our valuation of TPC and of the estate’s 20-percent interest in TPC is closer to the estate’s valuation than to respondent’s valuation. On the record before us, we believe it inappropriate to impose the accuracy-related penalty. The estate is not liable for the accuracy-related penalty. Accordingly, Decision will be entered under Rule 155.Page: Previous 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54
Last modified: May 25, 2011