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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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