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C. Whether Petitioner Is Liable for the Addition to Tax for
Negligence in 1981 and 1982
Respondent determined and contends that petitioner is liable
for the addition to tax for negligence under section 6653(a)(1)
for 1981 and 1982. Petitioner did not dispute respondent’s
contention at trial or on brief even though petitioner bears the
burden of proof on this issue. See Rule 142(a). We treat
petitioner’s failure to dispute respondent’s contention as his
concession that respondent’s determination is correct. See
Bradley v. Commissioner, 100 T.C. 367, 370 (1993); Stringer v.
Commissioner, 84 T.C. 693, 706 (1985), affd. without published
opinion 789 F.2d 917 (4th Cir. 1986); Bernstein v. Commissioner,
22 T.C. 1146, 1152 (1954), affd. per curiam 230 F.2d 603 (2d Cir.
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