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the advice of a tax professional. We conclude that petitioners
did not act with reasonable cause when they characterized the
royalty payments as long-term capital gains. As a result,
petitioners are liable for the section 6662(a) accuracy-related
penalty.
Contentions we have not addressed are irrelevant, moot, or
meritless.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011