Ernest I. Korchak - Page 39

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               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 correct                 






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