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for his lack of adequate records. He has advanced no arguments
to challenge respondent's determinations of additions to tax.
Consequently, he is deemed to have conceded them. Rule 149(b);
Murphy v. Commissioner, 103 T.C. 111, 119 (1994); Rothstein v.
Commissioner, 90 T.C. 488, 497 (1988). The additions to tax are
sustained for both years, subject to computational adjustments
under Rule 155.
For 1986, the deficiency and additions to tax must be
computed by reference to petitioner's separate tax liability,
determined without regard to items attributable to Mrs. Zuckerman
and using rates applicable to married persons filing separately.
For 1987, respondent has failed to satisfy her burden of proving
the $18,423 increase in unreported income asserted in her amended
answer and the correspondingly higher deficiency. The additions
to tax must be revised accordingly. For all relevant purposes,
petitioner is to be treated as having filed no return for 1987.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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