-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.Page: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
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