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We note that in petitioner’s reply brief, he considers
several issues conceded. We list below all the issues that
petitioner considered conceded in his reply brief.
The $1,755 gain in 1990 due to realized gains on foreclosed
properties was not listed as one of the issues not in
controversy. Another issue, gain on the sale of 53 lots, was
conceded by petitioner in his reply brief because it was not
petitioned. However, in his petition, petitioner alleged error
by respondent on the sale of the 53 lots and argued the issue in
his brief and reply brief. In light of the inconsistency, we
shall view the matter in the light most favorable to petitioner,
and we consider his arguments in the opinion.
With respect to the other issues considered not in
controversy by petitioner in his reply brief, we consider the
following issues conceded.
Petitioner concedes that in 1990, Farm & Grove earned income
of $168,567 on account of installment sales made during 1989.
Petitioner concedes that in 1990, Farm & Grove earned income of
$50,987 on account of installment sales made during 1990.
Petitioner concedes that his distributive share of income
from Farm & Grove in 1991 is a loss of $97,501, in 1992 is a loss
of $7,083, and in 1993 is a loss of $75,072.
Petitioner concedes that he is liable for an $8,259 self-
employment tax in 1991 and a $6,848 self-employment tax in 1993.
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