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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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