- 12 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
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