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determination that IRA is liable for the addition to tax under
section 6653(a)(1)(A) and (B) for 1985 on the underpayment from
the disallowed capital losses.
We also conclude that IRA failed to establish that it was
not negligent in claiming (1) the disallowed 1987 bad debt
deductions (Issue 26), (2) the disallowed 1987 ordinary losses
(Issue 27), and (3) the disallowed 1987 capital losses (Issue
28). IRA claimed the bad debt deductions with respect to the
promissory notes of Ballard and Lisle. There was no showing that
these debts were worthless. Moreover, IRA later pursued
collection efforts upon these notes, with the result that it
obtained payment from Ballard upon his notes and received Lisle's
renewed promise to pay his notes. Also, as to IRA's claimed
losses, IRA failed to show a reasonable basis for treating as
bona fide its purported sales of various assets to MAF.
Consequently, we sustain respondent's determination that IRA is
liable for the addition to tax under section 6653(a)(1)(A) and
(B) for 1987 on the underpayments from the disallowed losses and
bad debt deductions.
Lastly, we conclude that IRA failed to establish that it was
not negligent in claiming the disallowed 1988 $1,073,835 Decision
Holdings Form 4797 loss (Issue 23). IRA failed to show that it
was reasonable to claim that the TG limited partnership had a
basis of $1,091,641 in the assets that it transferred to Decision
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