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conveyed to the Partnership interest in the property." The check
written by petitioner to Mr. Razon includes in the memo section
the notation "Partnership Interest". Accordingly, the foregoing
considerations dissuade us from concluding that petitioner's
$30,000 payment was a loan as opposed to something else, e.g.,
the purchase of a partnership interest in Med-Center.
Consequently, we conclude that petitioners have not established
that the $30,000 payment to Mr. Razon constitutes a bona fide
debt that is deductible as a business bad debt. Petitioners have
not advanced any other theory upon which a deduction could be
premised. Accordingly, we hold that petitioners are not entitled
to a bad debt deduction in the amount of $30,000.
Lastly, we turn to the accuracy-related penalties determined
by respondent.10 In the notice of deficiency, respondent
determined that, on the basis of all of the adjustments in the
notice of deficiency, petitioners were liable for penalties
pursuant to section 6662(a) for taxable years 1990 and 1991. In
the amended answer, to reflect the adjustments related to
petitioners' underreporting and overreporting of income,
respondent increased the penalty for taxable year 1990 and
decreased the penalty for taxable year 1991. Accordingly, the
10 In their brief, petitioners argue that the sec. 6651(a)(1)
additions to tax should be reduced. At trial, however,
petitioners conceded the additions to tax. See supra note 1.
Accordingly, we do not consider petitioners' argument. In any
case, petitioners offered no evidence on the issue. Rule 142(a).
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