James K. Roberts - Page 12

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               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 when           




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