- 154 - decisions regarding the terms and structure of the cash transfers involving PK Ventures and its subsidiaries, PKVI LP, Zephyr, and the Zephyr purchasers. Consequently, any argument as to Rose’s reliance on the advice of tax professionals for the treatment of these cash transfers as debt rather than equity contributions or distributions is unconvincing. Based upon our analysis of the relevant facts and circumstances of these cases, we conclude that respondent’s imposition of accuracy-related penalties against the Roses must be sustained if the recalculation of the Roses’ income tax liabilities for 1990 through 1993 gives rise to substantial understatements of income tax for those years. We have considered the arguments of the parties that were not specifically addressed in this opinion. Those arguments are either without merit or irrelevant to our decision. To reflect the foregoing and the concessions of the parties, Decisions will be entered under Rule 155.Page: Previous 135 136 137 138 139 140 141 142 143 144 145 146 147 148 149 150 151 152 153 154
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