- 39 - Finally, petitioner’s attempts to monitor and salvage his Madison investment do not demonstrate that petitioner made his investment in Madison primarily to make a profit. His attempts are consistent with a concern about losing his $75,000 investment but do not disprove a concern about tax benefits. d. Conclusion When petitioner filed his 1982 return, he had some investment experience and the knowledge and experience associated with a successful career as a chemical engineer. However, petitioner has failed to establish that he reasonably investigated or analyzed Madison, or that he reasonably relied on competent and informed professional advice in deciding to invest in Madison and in claiming Madison’s tax benefits on his 1982 return. We hold, therefore, that petitioner is liable for the section 6653(a)(1) and (2) additions to tax for negligence. B. Section 6659 Under section 6659, a graduated addition to tax is imposed if an individual has an underpayment of at least $1,000 that is attributable to a valuation overstatement. Sec. 6659(a), (d). A valuation overstatement exists if the value of any property, or the adjusted basis of any property, claimed on any return exceeds 150 percent of the amount determined to be the correct amount of such valuation or adjusted basis. Sec. 6659(c)(1). If the claimed valuation exceeds 250 percent of the correctPage: Previous 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 Next
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