Raymond Strong - Page 2

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                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               CHABOT, Judge:  Respondent determined deficiencies in                  
          Federal individual income tax and additions to tax under sections           
          6653(a)1 (negligence, etc.) and 6661 (substantial understatement            
          of liability) against petitioner as follows:                                
                                   Additions to Tax                                   
         Year  Deficiency  Sec. 6653(a)(1)(A)  Sec. 6653(a)(1)(B) Sec. 6661           
         1987  $20,272        $1,014             1              $5,068                
         1 An amount equal to 50 percent of the interest due on $20,272.              
               After a deemed concession by petitioner,2 the issues for               
          decision are as follows:                                                    
                    (1) Whether petitioner is entitled to various itemized            
               employee business expense deductions;                                  
                    (2) Whether petitioner is liable for additions to tax             
               under section 6653(a); and                                             
                    (3) Whether petitioner is liable for additions to tax             
               under section 6661(a).                                                 


          1                                                                           
               Unless indicated otherwise, all section references are to              
          sections of the Internal Revenue Code of 1986 as in effect for              
          the year in issue.                                                          
          2                                                                           
               In the notice of deficiency, respondent disallowed                     
          petitioner’s claimed $250 tax preparation fee deduction.  At the            
          opening statement, this matter remained in dispute.  On the third           
          day of the trial, a witness was questioned about this matter.               
          However, petitioner, who has the burden of proof, did not argue             
          this matter on brief.  We treat petitioner’s failure to argue as,           
          in effect, a concession by petitioner of this matter.  See                  
          subpars. (4) and (5) of Rule 151(e); Sundstrand Corp. v.                    
          Commissioner, 96 T.C. 226, 344 (1991); Money v. Commissioner, 89            
          T.C. 46, 48 (1987).                                                         




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