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periodicals. Booth v. Commissioner, 108 T.C. 524, 578 (1997);
sec. 1.6662-4(d)(3)(iii), Income Tax Regs.
Petitioners’ position is not supported by any well-reasoned
construction of the relevant statutory provisions. There is no
substantial authority for their position that the purchase of the
Big Sur property and the subsequent sale of their Pacific Grove
property constituted an exchange. The cases petitioners have
cited on brief are readily distinguishable and to the extent they
are pertinent, undermine their position. Similarly, there is no
substantial authority for petitioners’ treatment of the
reallocated items.
Accordingly, we sustain respondent’s imposition of the
accuracy-related penalty.
To reflect the foregoing,
Decision will be entered for
respondent.
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