- 36 - $60,000”, and an automobile expense deduction of $15,220, conceding the remaining $14,657 of that issue. We have the power to treat as a default petitioner’s failure to comply with the Court’s rules and our specific oral directive. See Stringer v. Commissioner, 84 T.C. 693, 704-708 (1985), affd. without published opinion 789 F.2d 917 (4th Cir. 1986). However, petitioner’s actions have not been as egregious as those of the taxpayers and their counsel in Stringer. Also, we must recognize petitioner’s pro se status; Steve was not a lawyer. Accordingly we shall not default petitioner on these deductions. However, petitioner’s complete omission of this matter from its opening brief has had the effect of preventing respondent from replying to petitioner’s contentions. We conclude that, in the circumstances of the instant case, we shall not dismiss petitioner on the issue of business expense deductions--rather, we shall treat petitioner as having conclusively admitted the correctness of respondent’s proposed findings of fact bearing on the business expense deductions, except to the extent that petitioner’s statements in its answering brief are clearly inconsistent therewith, in which event we have resolved the inconsistencies based on our understanding of the record as a whole. See Estate of Jung v. Commissioner, 101 T.C. 412, 413 n.2 (1993).Page: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Next
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