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In his brief, petitioner contends only that his 1993
liabilities were discharged in bankruptcy. He does not address
any of the issues raised in the notice of deficiency. We may
treat those issues as conceded by petitioner. Rothstein v.
Commissioner, 90 T.C. 488, 497 (1988); Burbage v. Commissioner,
82 T.C. 546, 547 n.2 (1984), affd. 774 F.2d 644 (4th Cir. 1985);
Reaves v. Commissioner, 31 T.C. 690, 721-722 (1958), affd. 295
F.2d 336 (5th Cir. 1961). However, for reasons discussed next,
the result would be the same if we did not treat those issues as
conceded.
B. Whether Petitioner May Deduct Expenses for Labor and Taxes
in Amounts Greater Than Respondent Allowed
Petitioner deducted labor expenses of $63,000 on Schedule C
of his 1993 return. Respondent determined that petitioner did
not substantiate $25,519 of those expenses.5 At trial,
petitioner testified that he had no evidence to support his
position, but he said that the Social Security Administration
does.
Petitioner deducted $29,978.80 for “Taxes and Licenses” on
his 1993 return. Respondent determined that petitioner did not
substantiate $19,896 of that amount.6 Petitioner testified
5 Respondent concedes that petitioner had labor costs of
$37,481.
6 Respondent concedes that petitioner paid taxes and
licenses expenses of $10,082.80 in 1993.
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