- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008