-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 12
Last modified: November 10, 2007