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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.
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