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she could identify as reported by petitioners for 1992 (on their
belated return) and for 1993.
OPINION
Petitioners presented no evidence that they are entitled to
deductions beyond those allowed by respondent. Petitioners
stipulated that they do not contest any Schedule C, Profit or
Loss From Business, expenses not mentioned in the stipulation.
Petitioners contend that the amount of the penalty and additions
to tax determined by respondent should be reduced in accordance
with their claims of reduction in their taxable income.
Petitioners presented neither evidence nor argument about the
basis for imposition of the penalty and additions to tax. Thus,
they have conceded these issues. See, e.g., Money v.
Commissioner, 89 T.C. 46, 48 (1987). The issue remaining for
decision is whether certain legal fees received by petitioners
were taxable when received or were unearned “retainers” during
the years in issue.
Petitioners contend that certain rounded dollar amounts
included in respondent’s reconstruction of their income for 1992
and 1993 were unearned retainers rather than taxable income
during the years in issue. The only evidence in support of
petitioners’ contention is petitioner’s testimony. We need not
accept uncontroverted testimony at face value if it is
improbable, unreasonable, or questionable, see, e.g., Lovell &
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