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(1) for each of the years at issue that is attributable to the
claimed investment interest deduction relating to the 1991
interest payment and (2) for each of the years 1992 and 1993 that
is attributable to the claimed deduction relating to their
claimed 1992 worthless stock loss.
With respect to the investment interest deductions for 1991,
1992, and 1993 that are attributable to the 1991 interest payment
on the 1982 plan loan, we have rejected respondent's determina-
tions disallowing those deductions. Consequently, there are no
underpayments of income tax for those years that are attributable
to those deductions on which the accuracy-related penalties under
section 6662(a) may be imposed.
With respect to the 1992 and 1993 deductions relating to
petitioners' claimed 1992 worthless stock loss, petitioners
conceded at trial they are not entitled to those deductions.
However, they contend that they are not liable for 1992 and 1993
for the accuracy-related penalties under section 6662(a) that are
attributable to those deductions because they acted reasonably in
claiming them. Respondent disagrees. On the record before us,
we reject petitioners' contention.
During 1991, 1992, and 1993, petitioner, an orthodontist and
the sole shareholder of the Hickman corporation, was (1) the
director and the chairman of the board of directors of Midwest
Bank, (2) a director of National Bank of Harrah, Harrah
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