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determined under section 6651(a)(2) and asserted an increase in
the addition to tax determined under section 6651(a)(1) of $535
(for a total addition under that section of $5,352). At the
close of the trial, respondent made a motion to conform the
pleadings to the proof for the purpose of asserting an increased
deficiency based on an item of gross income of petitioner’s wife
(should we determine that petitioner and his wife made a joint
return) and certain items of gross income reported on a return
respondent received on November 10, 2003 (the Nov. 10 return).
The Nov. 10 return reported items of income of which respondent
had been unaware when he determined the deficiency shown in the
notice. We granted that motion. In his reply brief, respondent
concedes that there is no increased deficiency on account of any
item of income of petitioner’s wife. We accept that concession.
Taking into account various other concessions, the principal
issues remaining for decision are the amount of petitioner’s
gross income, whether petitioner is entitled to any deductions in
excess of the standard deduction and a deduction for a personal
exemption (and, if so, in what amounts), and the additions to tax
under sections 6651(a)(1) and 6654(a).1
1 By the amended petition, petitioner claims that the
notice does not credit him with an overpayment of taxes from 1999
nor does it reflect the appropriation of petitioner’s funds from
his account at the Federal Credit Union in 2002. Petitioner
filed a brief but failed to propose any facts or make any
argument with respect to an overpayment of taxes for 1999 or an
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