The Second Circuit Court of Appeals decided that the Tax Court had been too quick to dismiss a penalty under §6662 in the Estate of Thompson, decided last week, but that the Court was not forced to accept the taxpayer's valuation when it rejected the IRS's own expert's valuation even if the Court had decided the burden had been shifted under §7491.The materials for the podcast are available at http://www.edzollars.com/2007-08-26_Estate_Tax_Value.pdf .The podcast is sponsored by Leimberg Information Services, located on the web at http://www.leimbergservices.com .