- 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.
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Last modified: May 25, 2011