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for 1980 through 1989 was based on these records. These alleged
records, however, were not introduced into evidence.
In 1982, petitioner transferred his interest in the farm to
his parents, and petitioners therefore would not have realized
farm losses after 1982.
In summary, the credible evidence fails completely to
substantiate the claimed NOL carryforwards.
With regard to the additions to tax, petitioners have
conceded the additions to tax under section 6651(a)(1), and
petitioners present no credible argument as to the accuracy-
related penalties under section 6662(a). We sustain respondent’s
determination of the additions to tax and accuracy-related
penalties.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011