- 21 -
53. On November 27, 1996, Respondent
issued a notice of deficiency to Inga Wagner,
for tax years 1993 and 1994, in which Respondent
determined that Inga Wagner was liable for tax
on the payments she received from Petitioner,
Fred J. Pettid, in response to paragraph 1.f)
of the Annulment Agreement. * * *
Respondent objects to the above-quoted statements on the
ground that the determinations made by the Commissioner
with respect to the treatment of the payments in
Ms. Wagner's returns are not probative as to the treat-
ment of the payments in petitioner's returns.
Petitioner did not address respondent's objection on
brief, and, thus he has conceded it. See Lime Cola Co.
v. Commissioner, 22 T.C. 593, 606 (1954) (stating that
because petitioners did not address transferee liability
on brief, petitioners had conceded the issue); Levert v.
Commissioner, T.C. Memo. 1989-333 (stating that respondent
had conceded the taxpayer's liability for an addition to
tax that was determined in the notice of deficiency by
failing to discuss the issue on brief). Accordingly, we
sustain respondent's objection to the admission of
paragraph 6 of the stipulation of facts and paragraph 53
of the supplement to stipulation of facts.
Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 NextLast modified: May 25, 2011