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because our disallowance of the claimed NOL deduction is due to
petitioner’s failure to substantiate the NOL, for which
petitioner has offered no excuse.
Petitioner is liable for the accuracy-related penalty on the
full amount of the understatement of tax on his 1997 individual
Federal income tax return as determined herein.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011