-11- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12Last modified: November 10, 2007