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In the amended answer, respondent asserts revised deficiencies in
petitioners' Federal income tax and additions to tax and
accuracy-related penalties for the taxable years 1990 and 1991 as
follows:
Additions Accuracy-Related
to Tax Penalties
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1990 $92,568 $23,142 $18,514
1991 34,433 8,609 6,887
Unless otherwise indicated, all section and Code references
are to the Internal Revenue Code in effect for the years in
issue, and all Rule references are to the Tax Court Rules of
ractice and Procedure. After concessions,1 the issues to be
decided are as follows:2
1. Whether petitioners have substantiated their claimed
deductions on Schedule C for certain business expenses;
2. whether petitioners are entitled to certain passive
losses;
1 Petitioners conceded certain adjustments relating to
unreported interest income, an IRA distribution and a penalty
thereon, a self-employment health insurance deduction, and a
self-employment tax deduction. Additionally, at trial,
petitioners conceded the sec. 6651(a)(1) additions to tax. We
therefore do not consider those additions.
Respondent conceded that petitioners are entitled to
additional itemized deductions for real estate taxes in the
amount of $7,732, an interest expense in the amount of $15,968,
and charitable contributions in the amount of $7,715.
2 In their petition, petitioners disputed respondent's
disallowance of a Schedule A deduction for real estate taxes to
the extent of $6,106 for petitioners' 1990 taxable year.
Petitioners, however, make no argument on brief concerning that
issue. Consequently, we consider it to have been conceded.
Rybak v. Commissioner, 91 T.C. 524, 566 (1988).
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