Frederic W. Mercer - Page 4

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          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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