- 4 - 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 &Page: Previous 1 2 3 4 5 6 7 8 Next
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