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$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).
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