- 13 -13 limitations of section 1211. Sec. 166(d); United States v. Generes, supra; Shinefeld v. Commissioner, supra. Finally, we take note of the rhetorical question which petitioners pose in their reply brief: when Petitioners lost their residence to Agway as a result of the guarantee, who was the real victim? Agway or Petitioners? We are not unsympathetic to the plight of petitioners, who lost their home in the wake of the failure of Dutchess. Nevertheless, petitioners may only take those deductions authorized by the Internal Revenue Code. See Atkinson v. Commissioner, T.C. Memo. 1984-378. Additions to Tax and Penalties Petitioners failed on brief to raise the issue of the additions to tax and the penalty. By not addressing these issues, petitioners have effectively conceded them. Sundstrand Corp. v. Commissioner, 96 T.C. 226, 344 (1991). Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
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