Anand K. Verma - Page 2




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          After concessions,1 the issues for decision are:  (1) Whether the           
          corporate form of Export USA, Inc., should be disregarded; and              
          (2) whether petitioner2 is entitled to deductions on Schedule C,            
          Profit or Loss From Business, in excess of the amounts allowed by           
          respondent.                                                                 
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulated facts and the related exhibits are incorporated              
          herein by this reference.  At the time of filing the petition,              
          petitioner resided in Rockville, Maryland.                                  





               1    Petitioner reported gross receipts of $700 and claimed            
          cost of goods sold of $580 on Schedule C for 1996.  At trial,               
          petitioner conceded that both items should have been reported as            
          zero.                                                                       
               For 1996, respondent disallowed deductions of $37 for                  
          supplies and $170 for repairs and maintenance.  Petitioner did              
          not present evidence as to these expenses.  As a result,                    
          petitioner is deemed to have conceded these issues.  See Rules              
          142(a), 149(b); Burris v. Commissioner, T.C. Memo. 2001-49.                 
               2    Respondent also determined deficiencies for Vandana               
          Srivastava, petitioner’s former wife.  Ms. Srivastava was                   
          initially captioned as a party in this case.  At trial,                     
          petitioner stated that he signed the petition for Ms. Srivastava            
          without consulting with her.  Petitioner has not had contact with           
          his former wife since 1998, and the petition in this case was               
          filed on Mar. 8, 2000.                                                      
               Respondent moved to dismiss for lack of jurisdiction as to             
          Ms. Srivastava.  There being no indication that Ms. Srivastava              
          intended to file a timely petition, we granted respondent’s                 
          motion.  See Rule 13(a), (c); Abeles v. Commissioner, 90 T.C.               
          103, 106-109 (1988).                                                        




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