- 17 - however, have not shown what, if anything, they did to discern the authority on which they relied to justify the exclusion of the settlement proceeds from gross income or to determine the correct effective date of the amendments to section 104(a)(2). They have not identified any tax professionals that they consulted or on whom they relied. Because petitioners have not shown reasonable cause or good faith for their failure to include the settlement proceeds in gross income, the penalty determined by respondent is sustained. To reflect the foregoing and the concession of petitioners, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
Last modified: May 25, 2011