- 2 -
Additions to Tax and Penalties
Sec. Sec. Sec. Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6651(a)(2) 6653(a)(1) 6653(a)(1)(A) 6653(a)(1)(B)1 6662(a)
1985 $ 0 $ 212 $ 192 $ 66 $ — $ — $ —
1986 5,282 2,991 1,572 — 827 5,282 —
1987 1,376 332 52 — 74 1,376 —
1988 2,921 774 861 172 — — —
1989 16,214 2,178 2,420 — — — 3,190
1990 41,339 11,067 12,051 — — — 8,132
1991 37,713 6,681 1,710 — — — 7,543
1992 49,979 9,940 1,254 — — — 9,954
1993 141,892 30,766 1,050 — — — 28,378
150% of the interest due upon these amounts.
The issues for decision are: (1) The amount of losses
sustained by petitioners from their investments in, loans made
to, and loan guaranties for several pharmaceutical corporations
between 1979 and 1984; (2) the years petitioners were entitled to
recognize their losses; (3) whether the losses became part of the
personal bankruptcy estate of petitioners; (4) the amount of
carryover losses used by the personal bankruptcy estate of
petitioners; (5) the character of any remaining losses; and
(6) whether petitioners are liable for penalties and additions to
tax for 1985 through 1993. Other issues in the statutory notice
or in the petition have been abandoned by petitioners because
they failed to present any evidence or argument concerning them.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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Last modified: May 25, 2011