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The issues for decision are: (1) Whether petitioner
substantiated any rental expenses in excess of those allowed by
respondent. We find that he did to the extent stated herein.
(2) Whether petitioner is entitled to deduct more than 50 percent
of the expenses attributable to two rental properties he held as
a cotenant, where he paid all the expenses. We hold that he is
not.2 (3) Whether petitioner is liable for additions to tax for
substantial understatement of tax under section 6661. We hold
that he is to the extent stated herein.
In the petition, petitioner challenged the disallowance of a
portion of his charitable contribution. Petitioner did not
address this issue at trial or on brief. Thus, we find
petitioner has abandoned this claim. Rule 151(e)(4) and (5);
Petzoldt v. Commissioner, 92 T.C. 661, 683 (1989).
FINDINGS OF FACT
The stipulation of facts and attached exhibits are
incorporated herein by this reference. At the time the petition
herein was filed, petitioner resided in Richmond, Virginia.
Petitioner is single and filed an individual Federal income tax
return for the year at issue.
2
Respondent concedes that, if the Court determines that
petitioner is entitled to only 50 percent of the deductions
arising from the properties held in cotenancy, petitioner should
report only 50 percent of the income arising from such
properties.
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Last modified: May 25, 2011