-35- Issue 10. Other Adjustments Respondent contends that Strong Hope could not substantiate $41,194 of a claimed net operating loss carryover from 1988. Strong Hope did not contest this determination. We therefore sustain respondent's determination to the extent the adjustment may affect Strong Hope's 1989 tax year. Respondent also claims that Strong Hope should be taxed on rental income of $2,977 that it received from Celadon Restaurant in 1988. We do not have jurisdiction over Strong Hope's 1988 tax year. Accordingly, we do not sustain this adjustment. Issue 11. Strong Hope's Additions to Tax Respondent determined an addition to tax under section 6651(a)(1) and a penalty under section 6662 against Strong Hope for 1989. Section 6651(a)(1) imposes an addition to tax for failure to timely file a return. Strong Hope did not timely file its 1989 corporate tax return; thus, it is liable for the addition to tax under section 6651(a)(1). Pursuant to section 6662, a penalty is imposed on that portion of the underpayment that is attributable to negligence or disregard of rules and regulations or to substantial understatement. Like Ms. Ng, Strong Hope was uncooperative during the audit, did not provide adequate records, and misrepresented facts to respondent'sPage: 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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