- 29 - the $26 million loan. We reject petitioner’s arguments on this issue. For each of the years in issue and for each adjustment reflected in respondent’s notice of deficiency, respondent determined an accuracy-related penalty under section 6662(a) against petitioner for substantial understatements of tax. With regard to the disallowance for 1992 of the claimed $650,000 in acquisition-related expenditures that we sustain herein, petitioner has not demonstrated that it had substantial authority to support this claimed deduction, and we sustain imposition of this penalty. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29
Last modified: May 25, 2011