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Respondent determined a deficiency in petitioner’s Federal
income tax of $20,951 for 2003. Respondent conceded at trial
that petitioner is entitled to the dependency exemptions claimed
by petitioner. Because respondent conceded petitioner’s
entitlement to deductions for dependency exemptions, he must
recompute petitioner’s child tax credit and additional child tax
credit and submit to the Court a Rule 155 computation. At trial,
petitioner made no argument and presented no evidence that he:
(a) Is entitled to itemized deductions in excess of those allowed
by respondent, or (b) is not subject to self-employment tax. The
Court therefore deems those issues to have been conceded by
petitioner. See Rule 149(b); Rothstein v. Commissioner, 90 T.C.
488, 497 (1988); Cerone v. Commissioner, 87 T.C. 1, 2 n.1 (1986).
The issues remaining for decision are whether petitioner is
entitled to: (1) Deduct business expenses of $48,557, and
(2) the earned income credit.
Background
The stipulation of facts and the exhibits received into
evidence are incorporated herein by reference. At the time the
petition in this case was filed, petitioner resided in Thornton,
Colorado.
During 2003, petitioner was an engineer doing business as
S2E Consulting Engineers (S2E). Petitioner, under the name S2E,
received income reported on Form 1099-MISC, Miscellaneous Income,
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