Antim G. and Jane V. Straus - Page 12




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          in earnest about how they could recharacterize that distribution            
          so as to avoid its inclusion in their gross income.  We note,               
          with emphasis, that none of petitioners’ arguments to this end              
          are based in the Code or the regulations promulgated thereunder.            
          Accordingly, we find that petitioners did not act in good faith             
          with respect to any portion of the underpayment for their 2003              
          taxable year.  See sec. 6664(c)(1); sec. 1.6664-4(b)(1), Income             
          Tax Regs.                                                                   

                                                  Decision will be entered            
                                              for respondent.                         





























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