Jeffrey M. Guerrero and Genedine R. Guerrero - Page 9




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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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