- 18 - (d) The losses of petitioner's subsidiaries for the years prior to 1989 and 1990 comprise the fourth category of net operating loss carryforwards. We found claimed losses from two of these subsidiaries, Controlled Casting Systems Corp. and National Industrial Management Corp., unreliable and therefore disregarded them. As for the subsidiary losses the Court did allow (see supra p. 16), respondent's position was nevertheless justified based on the lack of adequate substantiation alone. See Porter v. Commissioner, T.C. Memo. 1986-465. No records, receipts, or invoices of the subsidiaries' business transactions were provided. Virtually the only documentary evidence of the pertinent loss year expenses of NII's subsidiaries for prior years is their unaudited books of original entry and general ledgers, and some canceled checks. Since the records provided by petitioner were not dispositive, respondent reasonably submitted the issue to the Court for resolution. See Santa Maria v. Commissioner, T.C. Memo. 1995-64; Grace Foreign Exch. Corp. v. Commissioner, T.C. Memo. 1995-63. (4) Negligence Penalty Based on Resulting Underpayments We held petitioner liable for accuracy-related penalties for negligence under section 6662(a) to the extent that the deductions the Court denied resulted in an underpayment for 1989Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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