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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).
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