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Because we have found that the subject transactions are
without substance or business purpose and that petitioner and its
officers were fully aware of the lack of bona fides of the
factual underpinnings for the transactions, there could be no
substantial authority or reasonable belief or cause on
petitioner’s part that would allow it to avoid the application of
the section 6662 penalties in this case.
In light of the foregoing and to reflect concessions by the
parties,
Decision will be entered
under Rule 155.
[REPORTER’S NOTE: This opinion was amended by Order dated
February 14, 2005.]
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