David S. and Melanie S. Alioto, (2011)

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David S. and Melanie S. Alioto, (2011)

T.C. Memo. 2011-151

UNITED STATES TAX COURT DAVID S. AND MELANIE S. ALIOTO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 11312-09. Filed June 29, 2011.

W. Michael Conway, for petitioners. Terry Serena, for respondent.

MEMORANDUM OPINION GOEKE, Judge: In this deficiency case, David and Melanie Alioto seek review of respondent's determination to deny deductions for business losses and theft losses for tax years 2005, 2006, and 2007 (the years in issue). As discussed below, we sustain respondent's determination to deny deductions but hold that petitioners are not liable for the accuracy-related penalties under section 6662(a).1

Background Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorp...

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