- 2 - 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011