- 16 - valuation or adjusted basis”. Sec. 6662(e)(1)(A). In other words, there is a gross valuation misstatement when the value or basis claimed on a return is 400 percent or more of the correct value or basis. Respondent determined that the full amounts of petitioner’s underpayments of tax were attributable to gross valuation misstatements. For 1994, petitioner’s underpayment was attributable to the disallowance of the Schedule F deductions for depreciation, “the cost basis of purchased cattle that died” (cost basis deduction), interest, and “sharecropboard” expenses. For 1995, petitioner’s underpayment was attributable to the disallowance of the Schedule F deductions for depreciation, interest, and “sharecropboard” expenses. Because the interest and sharecropboard expenses did not depend on valuation or basis statements, any underpayments of tax resulting from their disallowance cannot be based on gross valuation misstatements. See Jaroff v. Commissioner, T.C. Memo. 2004-276. However, the depreciation and cost basis deductions depended on petitioner’s reported bases in cattle. Therefore, 40-percent penalties may apply to petitioner’s underpayments resulting from the disallowance of the depreciation and cost basis deductions if the bases petitioner reported were gross valuation misstatements. See id.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011