Christopher K. and Brenda M. Cox, et al. - Page 25

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          accuracy-related penalty for substantial understatement of income           
          tax for 1995.  Accordingly, we sustain respondent’s                         
          determination.                                                              
          IV. Conclusion                                                              
               We hold that Christopher is entitled to increase his                   
          adjusted basis in Cox Tomato by $148,000, the amount he                     
          transferred to Cox Tomato in 1993.  We also hold that, as to all            
          other adjustments addressed in this opinion, respondent’s                   
          determinations must be sustained.                                           
               We have carefully considered all remaining arguments made by           
          the parties for contrary holdings and, to the extent not                    
          discussed, find them to be irrelevant or without merit.                     
               To reflect the foregoing,                                              


                                                  Decisions will be entered           
                                             under Rule 155.                          

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