Estate of Frank Johnson - Page 6




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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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