Paul S. Lindsey, Jr. and Kristen L. Lindsey - Page 17

                                       - 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