Big Hong Ng - Page 30

          contest this issue either at trial or in her posttrial brief.               
          Accordingly, we sustain respondent's determination in this regard.          
          Issue 6.  Net Operating Loss Deduction                                      
               Ms. Ng claimed a $13,182 net operating loss deduction in 1986          
          attributable to a loss carried over from 1985.  Respondent                  
          disallowed this deduction.  Ms. Ng has presented no evidence to             
          substantiate the loss.  Because Ms. Ng did not meet her burden of           
          proof, the deduction was properly disallowed.                               
          Issue 7.  Ms. Ng's Additions to Tax                                         
               Respondent determined that Ms. Ng is liable for an accuracy-           
          related penalty  and  for  additions  to  tax  for  negligence,             
          substantial understatement, failure to file timely returns, and             
          failure to pay estimated tax.                                               
               For 1986 and 1987, section 6653(a)(1)(A) imposes an addition           
          to tax of 5 percent of the amount of any underpayment due to                
          negligence or disregard of rules or regulations, and section                
          6653(a)(1)(B) provides for an addition of 50 percent of the                 
          interest payable under section 6601 on the portion of the                   
          underpayment attributable to negligence.  For 1988, a 5-percent             
          addition to tax for negligence or disregard of rules or regulations         
          applies pursuant to section 6653(a)(1).  For 1989, section 6662(a)          
          and (b)(1) and (2) imposes a penalty equal to 20 percent of the             
          portion of the underpayment that is attributable to negligence or           
          disregard of rules or regulations, or to substantial understatement         
          of tax.                                                                     

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