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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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