Michael J. Heckler, a.k.a. Michael Vonheckler and Charlotte A. Miska - Page 9

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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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