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Respondent determined that petitioners are liable for the
addition to tax under section 6651(a)(1) for each of the taxable
years at issue except for the taxable year ended February 28,
1993. In support of petitioners' position that respondent's
determinations are wrong, petitioners assert only: "Petitioners
believe that no additional tax is due and owing, and that there-
fore no deficiency penalties apply with respect to any year
because of the operation of the net operating loss carryover."
We have sustained respondent's determinations in the notice
regarding petitioners' consolidated return positions under
section 1031 and under section 1033, and petitioners conceded all
of the remaining determinations in the notice in the stipulation
of settled issues that the parties filed in this case (stipula-
tion of settled issues). On the record before us, we find that
petitioners have failed to show that respondent erred in making
the determinations in the notice under section 6651(a)(1).
Consequently, we sustain those determinations.
Accuracy-Related Penalty Under Section 6662(a)
Respondent determined that petitioners are liable for the
accuracy-related penalty under section 6662(a) for each of the
taxable years at issue except the taxable year ended February 28,
1993. Petitioners contend that those determinations are wrong
because (1) "no additional tax is due and owing, and * * *
therefore no accuracy related penalty applies"; (2) "there was
substantial authority for the position taken on the consolidated
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