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Addition to Tax Penalties
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1992 $7,892 $463 $1,578
1993 68,182 ---- 13,636
1994 70,526 ---- 14,105
After concessions,2 the issues for decision are:
(1) Whether petitioners sold their personal residence in
Danville, California (the Danville property) in April 1992,
resulting in capital gain and disallowance of deductions for
mortgage interest accruing after that date;
(2) whether petitioners are entitled to claim losses for tax
years 1992 and 1993 with respect to certain rental real property
they owned in San Jose, California (the San Jose property);
(3) whether petitioners had legal or equitable ownership of
certain real property in Milpitas, California (the Milpitas
property) so as to support their claimed deductions for mortgage
interest and property taxes with respect to the property for tax
year 1994;
2 Respondent disallowed petitioners’ unreimbursed employee
expense deductions in the amounts of $5,508, $9,119, and $9,158,
for 1992, 1993, and 1994, respectively. Respondent also asserted
a penalty under sec. 6651(a)(1) for petitioners' failure to
timely file their 1992 joint Federal income tax return.
Petitioners failed to address these issues both at trial and on
brief. We treat petitioners’ failure to press these issues as,
in effect, conceding them. See Rule 151(e)(4) and (5);
Sundstrand Corp. & Subs. v. Commissioner, 96 T.C. 226, 344
(1991); Rybak v. Commissioner, 91 T.C. 524, 566 n.19 (1988);
Money v. Commissioner, 89 T.C. 46, 48 (1987). The parties
conceded several other issues in the stipulation of settled
issues.
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