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however, they claimed their carryover losses from 1991 even
though they had not made any capital contributions or loans in
1991 to increase their bases. Petitioners provided no
explanation for their actions and accordingly have failed to show
that their actions were reasonable and not careless or made with
intentional disregard of rules or regulations. Petitioners are
liable for the section 6662(a) penalties for the 1992 tax year.
We have considered all other arguments of the parties, and,
to the extent not addressed herein, we find them to be either
moot, without merit, or irrelevant.
To reflect the foregoing,
Decisions will be entered for
respondent.
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