Rjt Investments X Randall J. Thompson Tax Matters Partner v. Commissioner of Internal Revenue

WOLLMAN, Circuit Judge.

RJT Investments X, LLC (RJT) and its tax matters partner, Randall Thompson, appeal from the judgment of the United States Tax Court 1 sustaining (1) adjustments sought by the Commissioner of the Internal Revenue Service (the “Commissioner” or the “IRS”) to RJT’s 2001 tax return and (2) the imposition of a penalty for income tax underpayment resulting from gross valuation misstatements and negligence or disregard of rules and regulations pursuant to 26 U.S.C. § 6662(a), (b)(1), (b)(3), (c), (e) and (h). We affirm.

I. Background

Thompson formed RJT on October 11, 2001. On…