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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.
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Last modified: May 25, 2011