Florida Industries Investment Corporation and Subsidiaries - Page 50




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          We are unwilling to rely on the foregoing testimony to establish             
          that there was reasonable cause and that petitioners acted in                
          good faith in taking their consolidated return positions under               
          section 1031, under section 1033, and with respect to the other              
          determinations in the notice which petitioners conceded.                     
               On the record before us, we find that the petitioners have              
          failed to establish any error in respondent's determinations that            
          they are liable for the accuracy-related penalty under section               
          6662(a) for each of the taxable years at issue except the taxable            
          year ended February 28, 1993.                                                
               To reflect the foregoing and the concessions of petitioners,            
                                        Decision will be entered for                   
                                   respondent.                                         

























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