- 4 - he has failed to establish error in respondent's determinations under sections 6651(a)(1) and 6654. Accordingly, we reject petitioner's claim for net operating loss deductions for the years at issue and sustain respondent's determinations imposing the additions to tax under sections 6651(a)(1) and 6654 for those years. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4
Last modified: May 25, 2011