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of the years 1986, 1988, 1990, and 1991, failed to file a Federal
income tax return for any of those years.
Although the record does not disclose the exact nature of
his activities, during the 1980's, petitioner was involved in
real estate, real estate investments, and real estate securities.
Petitioner has the burden to show that he is entitled to the
net operating loss deductions that he is claiming and that he is
not liable for the additions to tax determined under sections
6651(a)(1) and 6654. Rule 142(a).
Except for his general and conclusory testimony that he had
a net operating loss of approximately $55,000 for his taxable
year 1985, petitioner has presented no evidence to establish the
income that he had and the expenses to which he is entitled for
1985, and consequently he has not shown that he had a net
operating loss for that year.4
Petitioner presented no evidence and advanced no argument
regarding the additions to tax determined in the notice.
On the record before us, we find that petitioner has failed
to show that he is entitled to the net operating loss deductions
that he is claiming for the years at issue. We further find that
4 Assuming arguendo that petitioner had established that he
had a net operating loss for 1985, he has not shown (1) that
that loss was not fully utilized when it was carried back to
each of the three years preceding 1985 as required by sec.
172(b)(1)(A) or (2) that he made an election to relinquish the
carryback of that loss pursuant to sec. 172(b)(3)(C).
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