Allen C. Chamberlin and Martha L. Chamberlin - Page 26

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          profits through dividends and the increase in value of his                  
          investment than to that of a promoter who buys and sells                    
          companies as if they were inventory.  We conclude that petitioner           
          was not in the trade or business of promoting business ventures             
          in the health care industry.  Thus, petitioners may not deduct as           
          a business bad debt the $450,000 loss.                                      
               We have considered all other arguments of petitioners, and             
          they are addressed by the consideration of lack of remaining                
          carryover losses belonging to the bankruptcy estate or otherwise            
          lack merit.                                                                 
                           Additions to Tax and Penalties                             
               Respondent determined additions to tax for failure to file             
          tax returns under section 6651(a)(1) and additions to tax for               
          failure to make timely payment of taxes under section 6651(a)(2).           
          Respondent also determined additions to tax for negligence under            
          section 6653(a)(1), additions to tax for negligence under section           
          6653(a)(1)(A) and (B), and accuracy-related penalties for                   
          negligence or substantial understatements under section 6662(a).            
          Additions to Tax for Failure To File Timely                                 
          a Tax Return and Pay Tax Liability                                          
               Section 6651(a)(1) provides for an addition to tax of                  
          5 percent of the tax required to be shown on the return for each            
          month or fraction thereof for which there is a failure to file,             
          not to exceed 25 percent.  Section 6651(a)(2) provides for an               

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