- 2 -
respectively.
The issues remaining for decision for the year at issue
are:2
(1) Are petitioners entitled to a deduction under section
170(a) for a claimed noncash charitable contribution? We hold
that they are not.
(2) Are petitioners liable for the accuracy-related penalty
under section 6662(a)? We hold that they are.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioners resided in Dayton, Ohio (Dayton), at the time
the petition was filed.
Petitioner Robert E. Signom, II (Mr. Signom) received an
undergraduate degree in business administration in 1967 from
Miami University of Ohio. Thereafter, he attended law school,
having matriculated for two years at Washington University in St.
Louis and for one year at Ohio State University, from which he
received a law degree in 1970. Petitioner Lola Signom (Ms.
Signom) received an undergraduate degree in journalism from Ohio
University.
2Petitioners conceded certain determinations in the notice
of deficiency (notice) and did not present evidence at trial or
make any argument on brief with respect to certain other determi-
nations in the notice. We conclude that petitioners have aban-
doned contesting those determinations in the notice as to which
they presented no evidence at trial or make no argument on brief.
See Rybak v. Commissioner, 91 T.C. 524, 566 n.19 (1988).
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