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Commissioner, 84 T.C. 693, 706 (1985) (“On numerous
occasions, we in essence have defaulted or dismissed
issues for failure to brief them. Generally, we have
accomplished this result by considering the issue waived or
conceded.”), affd. without published opinion 789 F.2d 917
(4th Cir. 1986); Lime Cola Co. v. Commissioner, 22 T.C.
593, 606 (1954) (“Petitioners in their brief do not argue
anything about transferee liability; and, although they do
not expressly abandon the issue of transferee liability,
we presume they no longer press it.”); Stonegate of
Blacksburg, Inc. v. Commissioner, T.C. Memo. 1974-213
(“Since petitioner did not consider this issue in either
its original or reply briefs, we consider it to have been
conceded.”).
Second, petitioners’ entire argument concerning the
unreported income issue is directed toward the payments
that petitioner received from BMAP. Petitioners raise no
defense concerning the payments that petitioner received
from the four other entities, Sing-Sing, Gerre Trans,
Richman & Sons, and Camden City Probation, that are
identified in the notices of deficiency. Accordingly,
we hereby sustain respondent’s determination as to the
payments received from those entities.
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