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substantially understated their tax for 1989 by claiming a
carryover from the same alleged loss.
Petitioners conceded the deduction for 1989 because the
carryover loss had been fully utilized prior thereto5. We have
sustained respondent’s determination that petitioners are liable
for the section 6653(a)(1) and section 6661 addition to tax for
1988. We likewise sustain respondent’s determination that
petitioners are liable for the accuracy-related penalty under
section 6662(a) for 1989.
To reflect the foregoing,
Decisions will be entered
under Rule 155.
5 Petitioners had failed to file an election to
relinquish the carryback pursuant to sec. 172(b)(3)(C). See
discussion supra, p. 8.
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