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Additions to Tax and Penalties
Sec. Sec. Sec.
Taxable Year Deficiency 6651(a)(1) 6653(a)(1) 6662
1988 $11,775 $2,361 $662 –-
1989 18,818 4,118 –- $3,764
1990 19,613 –- –- 3,923
1991 12,827 -- -- 2,565
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years at issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
After a concession,1 the issues for decision are:
(1) Whether petitioners were engaged in a trade or business
involving equipment rental or metal fabrication so as to be
entitled to deductions for depreciation and other business
expenses; (2) whether petitioners are entitled to claim certain
net operating losses for taxable years 1988 and 1989; (3) whether
petitioners are liable for the addition to tax under section
6651(a) for taxable years 1988 and 1989; and (4) whether
petitioners are liable for the addition to tax under section
6653(a)(1) for taxable year 1988 and the penalty under section
6662 for taxable years 1989, 1990, and 1991.
1 Petitioners failed to present any evidence to dispute
respondent’s determination that they are liable for self-
employment tax. They have not addressed the issue on brief. We
treat petitioners’ failure to address this issue, in effect, as a
concession. See Rule 151(e)(4) and (5); Sundstrand Corp. & Subs.
v. Commissioner, 96 T.C. 226, 344 (1991); Money v. Commissioner,
89 T.C. 46, 48 (1987).
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Last modified: May 25, 2011