- 6 - penalties to the extent of the net value of assets they purportedly received from decedents,2 as follows: Docket Net Value of No. Transferee Assets Asserted 14520-97 Larry T. Johnson $861,668 14521-97 Sylvia Johnson 229,685 14522-97 Ronnie Johnson 766,003 The issues for decision are as follows: (1) Whether the statute of limitations bars assessment of the deficiencies for each of the years in issue, (2) whether decedents understated their income for each of the years in issue, (3) whether decedents’ capital gain income should be increased for 1989,3 (4) whether decedents’ taxable Social Security income should be increased for each of the years 1985 through 1990, (5) whether decedents’ self-employment taxes under section 1401 should be increased for each of the years in issue, 2 A transferee’s liability generally is limited to the value of the assets received from the transferor. See Hagaman v. Commissioner, 100 T.C. 180 n.1 (1993). 3 Respondent also identifies as an issue the question of whether decedents’ capital gain income for 1986 should be increased. We assume that respondent meant 1985 inasmuch as respondent made a $6 adjustment to capital gain income for that year, but no adjustment to capital gain income for 1986. In their briefs, petitioners do not address the issue of capital gain income for either 1985 or 1986. Accordingly, we deem that issue conceded by them. See Rule 151(e)(4) and (5); Petzoldt v. Commissioner, 92 T.C. 661, 683 (1989); Money v. Commissioner, 89 T.C. 46, 48 (1987).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011