- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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