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deficiencies pursuant to section 6662(a)2 and (h).
Alternatively, respondent alleges that those petitioners are
liable for penalties for substantial valuation misstatements
equal to 20 percent of the deficiencies pursuant to section
6662(a), (b)(3), and (e)(1)(A).
The issues common to all petitioners are whether: (1)
Petitioners are entitled to the charitable contribution
deductions claimed under section 170(a)(1) for the transfer to a
tax-exempt medical foundation of intangible assets associated
with each petitioner physician's medical practice, and (2) the
individual petitioners are liable for the 40-percent accuracy-
related penalty for gross valuation misstatements pursuant to
section 6662(a) and (h) or, alternatively, for the 20-percent
penalty for substantial valuation misstatements pursuant to
section 6662(a), (b)(3), and (e)(1)(A).3 In addition, the
following issues involve certain of petitioners as indicated,
whether: (1) Petitioners Daniel J. and Jean C. Kennedy (the
Kennedys) underreported Dr. Kennedy's 1994 gross receipts by
$3,760 on Schedule C, Profit or Loss From Business, and (2)
2 Unless otherwise noted, all section references are to the
Internal Revenue Code of 1986 as in effect for the year in issue,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
3 The deficiencies also reflect adjustments that are
derivative of the principal adjustments, are not directly
disputed by petitioners, and will be resolved by our resolution
of the principal adjustments. We do not further discuss those
derivative adjustments.
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