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The second issue for decision is whether petitioners are
entitled to an investment tax credit for 1992.
Petitioners did not claim an investment tax credit on their
1992 return. Petitioners contend that they have an unused
investment tax credit in the amount of $1,839 which was
originally claimed on their 1984 return.
Petitioners have not proved that the allegedly unused credit
was not absorbed as a carryback to any of their 3 taxable years
preceding their 1984 taxable year (1981, 1982, and 1983). Sec.
39(a). Moreover, they have not proved that any remaining amount
was not absorbed as a carryforward to any of the 7 taxable years
following their 1984 taxable year (1985 through 1991) but
preceding the taxable year in issue (1992). Id. Therefore, we
have no way of determining the proper amount, if any, of the
alleged credit which may be used as a carryforward to 1992.
Accordingly, we hold that petitioners are not entitled to an
investment tax credit for 1992.
The fourth issue for decision is whether petitioners are
liable for the section 6662(a) accuracy-related penalty.
Respondent's determinations of negligence are presumed to be
correct, and petitioners bear the burden of proving that the
penalties do not apply. Rule 142(a); Welch v. Helvering, 290
U.S. at 115; Bixby v. Commissioner, 58 T.C. 757, 791-792 (1972).
Section 6662(a) imposes a 20-percent penalty on the portion
of an underpayment attributable to any one of various factors,
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