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In general, section 465(a) allows losses “only to the extent
of the aggregate amount with respect to which the taxpayer is at
risk * * * for such activity”. Sec. 465(a)(1). Section 46(c)(8)
generally reduces a taxpayer’s credit base in property by the
amount of nonqualified nonrecourse financing with respect to such
property--where the taxpayer and the property are subject to the
limitations of section 465--thereby limiting the amount of
general business credit available to the taxpayer. Sec 38(a),
(b)(1); sec. 46(a), (c)(1), (c)(8)(A) and (B).
Petitioners have not presented any evidence or arguments
concerning the imposition of tax motivated interest on the
deficiencies. Specifically, petitioners have not argued, and
nothing in the record indicates, that respondent is in error
concerning his determinations that petitioners did not meet the
“at risk” requirements of section 465 with respect to the farming
losses, and that the general business credit was disallowed
pursuant to section 46(c)(8). We therefore sustain respondent’s
determination that the section 6621(c) increased rate of interest
is applicable with respect to the deficiencies in petitioners’
taxable years 1984, 1985, 1987, and 1988.9 See Rule 142(a).
9Sec. 6621(c) does not apply with respect to petitioners’
taxable year 1989. See supra note 3.
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