Edward C. Tietig - Page 54

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               Finally, petitioner asserted in his petition that a                    
          deduction is allowable for 1990 for an unprocessed claim for                
          refund filed with the Internal Revenue Service.  Petitioner                 
          introduced no evidence at trial regarding this issue, and                   
          petitioner’s opening and reply briefs make no reference to this             
          issue.  Since this possible issue was not argued on brief, it is            
          deemed conceded.  See Money v. Commissioner, 89 T.C. 46 (1987).             

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