- 68 -
ment. Thus, no adjustment to Mrs. Lemons' self-employment
tax for 1987 is before the Court. In passing, we note that
respondent's brief, quoted above, states that Mrs. Lemons'
self-employment tax for 1987 should be increased "at the
conclusion of this matter under T.C. Rule 155."
Respondent's brief also states that this "adjustment"
is "unrelated to the other adjustments in the notices."
However, if this adjustment is unrelated to the other
adjustments in the notice, it would appear to be a new
issue which cannot be raised for the first time either
in a post-trial brief or in a Rule 155 proceeding. See
Bankers' Pocahontas Coal Co. v. Burnet, 287 U.S. 308
(1932); Cloes v. Commissioner, 79 T.C. 933 (1982);
Estate of Papson v. Commissioner, 74 T.C. 1338, 1340
(1980); Estate of Stein v. Commissioner, 40 T.C. 275
(1963).
To reflect the foregoing and concessions,
Decisions will be entered
under Rule 155.
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