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determination that petitioners were not entitled to a 1982
investment tax credit that they claimed was attributable to their
interest in a limited partnership, Catamount Associates
(Catamount), and portions of which they carried back to each of
the subject years. Following actual and deemed concessions by
petitioners, we must decide whether respondent is barred from
assessing any of the amounts set forth in the notices of
deficiency for the subject years.1 Petitioners assert that
respondent is barred by either the 3-year period of limitation
under section 6501 or a prior proceeding in this Court involving
petitioners’ individual income tax liability for 1980.
We hold that respondent may assess the additions to tax set
forth in the notices of deficiency. Unless otherwise indicated,
section references are to the Internal Revenue Code in effect for
the relevant years. Rule references are to the Tax Court Rules
of Practice and Procedure.
1 Petitioners set forth in their petition numerous
allegations of error on the part of respondent. In their brief,
petitioners limited their argument to the issue discussed herein.
Under the facts of this case, we consider petitioners to have
conceded all of their other allegations of error. See, e.g.,
Money v. Commissioner, 89 T.C. 46, 48 (1987); Burbage v.
Commissioner, 82 T.C. 546, 547 n.2 (1984), affd. 774 F.2d 644
(4th Cir. 1985); Zimmerman v. Commissioner, 67 T.C. 94, 104 n.7
(1976).
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