- 12 - B. Schedule A Deductions 1. 1987 a. Interest In her notice of deficiency, respondent included an adjustment disallowing an interest deduction in the amount of $726. Although petitioner has assigned error with respect to that adjustment, petitioner has failed to address that adjustment on brief. Therefore, we conclude that petitioner has abandoned the interest issue, and we sustain so much of respondent’s determination as relates thereto. See Bernstein v. Commissioner, 22 T.C. 1146, 1152 (1954) (holding against the taxpayer with respect to an issue because, among other things, the taxpayer did not press the issue on brief), affd. 230 F.2d 603 (2d Cir. 1956); Lime Cola Co. v. Commissioner, 22 T.C. 593, 606 (1954) ("Petitioners in their brief do not argue anything about * * * [the issue]; and, although they do not expressly abandon the issue * * * we presume they no longer press it."). b. Contribution In her notice of deficiency, respondent included an adjustment disallowing a charitable contribution deduction in the amount of $3,175. That amount is reflected as a cash contribution on Schedule A, Itemized Deductions, attached to petitioner’s Form 1040, U.S. Individual Income Tax Return 1987. Petitioner testified that he had no specific recollection of cash contributions except for change he put into a collection cup whenPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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