Richard T. Stanley, Sr. and Miriam Stanley - Page 2




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          penalties for negligence under section 6662(a) for each of these            
          years.  Unless otherwise stated, section references are to the              
          Internal Revenue Code in effect for the years in issue.  Rule               
          references are to the Tax Court Rules of Practice and Procedure.            
          Amounts are rounded to the nearest dollar.  Miriam Stanley is a             
          party to this action by reason of having filed income tax returns           
          jointly with petitioner Richard T. Stanley, Sr.  References                 
          hereinafter to petitioner relate to Mr. Stanley.                            
               This case was submitted to the Court without trial pursuant            
          to Rule 122(a).  After moving jointly to submit this case for               
          trial on the basis of the pleadings and the facts recited and the           
          exhibits in the stipulation of facts, petitioners' attorney was             
          ordered to file a brief no later than November 13, 1998.  Despite           
          repeated admonitions that the brief was required and overdue,               
          petitioner's attorney has failed to file with the Court his brief           
          in this matter.  We must decide the case, therefore, on the                 
          record before us, without benefit of petitioner's arguments.                
               Following concessions by the parties, we must decide whether           
          petitioner is entitled to deduct nonbusiness bad debts of                   
          $498,500 for 1993.  We must also decide whether petitioner is               
          entitled to deduct business bad debts of $2,041,409 for 1994.               
          Finally we must decide whether petitioner is subject to                     
          accuracy-related penalties for negligence pursuant to section               
          6662(a) for the years 1992 through 1994.  We hold that petitioner           
          is not entitled to the contested deductions and that petitioners            




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