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moving from office to office fails to show that this was a loss
beyond his control as contemplated by section 1.274-5(c)(5),
Income Tax Regs. Silver v. Commissioner, T.C. Memo. 1972-102.
Nor has petitioner reasonably reconstructed his expenditures
under the regulations. Gizzi v. Commissioner, 65 T.C. 342, 345-6
(1975). Accordingly, we must sustain respondent’s determination
on this issue.
As to the rent deduction issue, respondent allowed $3,825
and disallowed $3,675 of the amount claimed as a deduction. When
we reached this issue at trial, we asked petitioner whether he
could provide any evidence to establish that he was entitled to
an additional amount over and above what respondent allowed. The
response by petitioner was “No, I have nothing else to submit.”
We deem this issue conceded by petitioners and sustain
respondent’s determination as to rental expenses.
With respect to determinations of gain or loss, section
1001(a) provides that the gain from the sale or other disposition
of property shall be the excess of the amount realized therefrom
over the adjusted basis provided in section 1011 for determining
gain, and the loss shall be the excess of the adjusted basis
provided in such section for determining loss over the amount
realized. Sections 1011 and 1012 provide, insofar as relevant in
this case, that the adjusted basis of the property shall be its
cost. Section 1016 provides that proper adjustments shall be
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