- 30 -                                         
          petitioners did not prove that they had a basis in the collection           
          sold and, thus, petitioners had a zero basis in the cars.                   
          Therefore, we sustain respondent's determination and find that              
          petitioners are liable for the 40-percent accuracy-related                  
          penalty on the adjusted basis of the muscle car collection.                 
                                                  Decision will be entered            
                                             under Rule 155.                          
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