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of first impression involving unclear statutory language.
Hitchins v. Commissioner, 103 T.C. 711, 720 (1994).
Since this is the first time we have considered the rollover
requirements as to the specific character of the property to be
transferred, we find for petitioner as to the negligence penalty
imposed on the portion of the underpayment attributable to the
distributions used to purchase the stock. The record contains no
facts pertaining to petitioner's failure to report any portion of
the distributions. Thus, we find petitioner liable for the
negligence penalty imposed on the portion of the underpayment
attributable to the $102,519 not used to purchase the stock.
In keeping with the above holdings,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011