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litigation costs claimed by petitioner are reasonable. Sec.
7430(a)(2), (c)(1).
Neither party has requested a hearing, and we conclude that
a hearing is not necessary. Rule 232(a). Accordingly, we decide
petitioner's motion on the basis of the motion, respondent's
notice of objection to petitioner's motion, petitioner's reply to
respondent's notice of objection, and affidavits submitted by
petitioner.
Respondent issued a notice of deficiency dated June 27,
1995, determining deficiencies in petitioner's Federal income tax
and accuracy-related penalties as follows:
Accuracy-Related Penalties
Year Deficiency Sec. 6662(a)
1990 $468,857 $93,771
1991 67,269 13,454
1992 36,250 7,250
The adjustments contained in the notice of deficiency relate to
respondent's determination that petitioner failed to report as
income distributions received from Development Southwest
Investments, Inc., his solely owned S corporation; that
petitioner failed to report cancellation of indebtedness income
relating to the activities of Double J & T Ranch (J & T), a joint
venture in which petitioner was a member; that petitioner was not
entitled to claimed losses in connection with the activities of J
& T, pursuant to the "at risk" rules of section 465; and that
petitioner was not entitled to capital losses claimed in
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