- 40 - Glenshaw Glass Co., 348 U.S. 426 (1955). Petitioners have failed to do so. Accordingly, we sustain respondent’s determination. Dividend Income Respondent determined that for 1992 petitioners overstated their dividend income by $8,732. At trial, petitioner appeared to concede this issue. In the stipulation of agreed adjustments filed with the Court after trial, however, the parties included this item in the list of adjustments still at issue. Petitioners nevertheless failed to address this issue in their briefs. Accordingly, we treat the dividend income issue as conceded by petitioners, and we sustain respondent’s determination on this issue. See Rule 151(e)(4) and (5); Petzoldt v. Commissioner, 92 T.C. at 683; Money v. Commissioner, 89 T.C. at 48. Additions to Tax for Failure To Timely File Tax Returns Respondent determined that for 1989 and 1990 petitioners were liable for additions to tax under section 6651(a)(1) because they failed to file timely returns or to show that they had 15(...continued) that the burden of production regarding the Computerland prize should shift to respondent under sec. 6201(d), petitioner offered no evidence that he fully cooperated with respondent, and the record in this case supports a conclusion that petitioner did not fully cooperate with the Commissioner as required by sec. 6201(d). See Ketler v. Commissioner, T.C. Memo. 1999-68; Andrews v. Commissioner, T.C. Memo. 1998-316; Hardy v. Commissioner, T.C. Memo. 1997-97, affd. 181 F.3d 1002 (9th Cir. 1999).Page: Previous 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 Next
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