-267-
In any event, we conclude that respondent has satisfied any
burden of production he might have under section 7491(c) with
respect to the appropriateness of applying accuracy-related
penalties in the instant cases. Consequently, petitioner must
come forward with evidence sufficient to persuade the Court that
respondent’s penalty determinations are incorrect. Higbee v.
Commissioner, supra at 447.
B. Gross Valuation Misstatements
A 20-percent accuracy-related penalty applies to the extent
that any portion of an underpayment is attributable to any
“substantial valuation misstatement”. Sec. 6662(a) and (b)(3).
There is a “substantial valuation misstatement” if “the value of
any property (or the adjusted basis of any property) claimed on
any return of tax imposed * * * is 200 percent or more of the
amount determined to be the correct amount of such valuation or
adjusted basis (as the case may be)”. Sec. 6662(e)(1)(A). In
the case of a “gross valuation misstatement”, the penalty
increases from 20 to 40 percent. There is a “gross valuation
misstatement” if the value of any property (or the adjusted basis
of any property) claimed on any return of tax imposed is 400
percent or more of the amount determined to be the correct amount
of such valuation or adjusted basis (as the case may be). Sec.
6662(e)(1) and (h)(2). In the case of multiple valuation
misstatements, the determination of whether there is a
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