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Subsequent to the filing of a timely petition, respondent’s
motion to strike with respect to the section 6651(a)(2)1
additions to tax was granted.
After concessions, the issues remaining for decision2 are:
(1) Whether petitioner received nonemployee compensation of
$120,200 during 1988. We hold that she did.
(2) Whether petitioner is entitled to certain deductions
she claims for her 1988 and 1993 tax years. We hold that she is
not.
(3) Whether we have jurisdiction to order a refund or
credit to petitioner of a $3,441 overpayment she made with
respect to her 1989 Federal income tax liability. We hold that
we do not.
1 Unless otherwise noted, 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.
2 Petitioner claimed, in her petition, that she “may be
entitled to a bad debt or other deduction” arising from a note
she received in exchange for a portion of her interest in Bankers
Mortgage Group, Inc. Petitioner did not present any evidence or
make any further argument regarding this claim. Accordingly, we
treat this claim as abandoned and do not address it herein. See
Bradley v. Commissioner, 100 T.C. 367, 370 (1993); Ryback v.
Commissioner, 91 T.C. 524, 566 n.19 (1988).
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