- 9 - they reasonably believe that such treatment was more likely than not the proper tax treatment. As petitioners failed to cite any authority or present any evidence to overcome respondent's determination on this issue, we conclude that no substantial authority exists for the tax treatment of items related to Irving & Co. and that petitioners did not reasonably believe that their treatment of the items was more likely than not correct. Accordingly, respondent is sustained on this issue. Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011