- 13 - deductions and credits were derived, petitioners appear to have conceded the merits of these items. Furthermore, petitioners did not set forth clear and concise assignments of error in their petitions concerning these items. See Rule 34(b)(4). In any event, petitioners have provided no substantiation or other evidence concerning the farming losses or the general business credits related thereto. In the absence of substantiation, petitioners are not entitled to the farming loss deductions or the credits. Sec. 6001; sec. 1.6001-1(a), (e), Income Tax Regs. We therefore sustain respondent’s determinations as to the underlying deficiencies in these cases. II. Additions to Tax A. Valuation Overstatements With respect to petitioners’ taxable years 1984, 1985, 1987, and 1988, section 6659(a)5 generally imposes an addition to tax on any portion of an underpayment of income tax by an individual which is “attributable to a valuation overstatement”. A “valuation overstatement” exists “if the value of any property, or the adjusted basis of any property, claimed on any return is 150 percent or more of the amount determined to be the correct amount”. Sec. 6659(c)(1). The addition to tax applies only if 5References to sec. 6659 are to sec. 6659 as in effect with respect to returns that were filed after Dec. 31, 1981, and that were due before Jan. 1, 1990. See Economic Recovery Tax Act of 1981, Pub. L. 97-34, sec. 722(a), 95 Stat. 341; OBRA sec. 7721, 103 Stat. 2395.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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