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Revenue Code in effect for the years in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
Respondent determined deficiencies in petitioner’s Federal
income taxes in the amounts of $1,339 and $1,744 and accuracy-
related penalties under section 6662(a) of $267.80 and $348.80
for 1996 and 1997, respectively. After concessions,1 the issues
for decision are: (1) Whether petitioner is entitled to
dependency exemption deductions for her father and brother; (2)
whether petitioner is entitled to a deduction for medical
expenses; (3) whether petitioner is entitled to deductions from
her real property rental activities in excess of the amounts
allowed by respondent; and (4) whether petitioner is liable for
the accuracy-related penalties.
Background
Some of the facts have been stipulated, and they are so
found. The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time of filing her
petition, petitioner resided in Lake Wales, Florida.
1 For 1996, respondent determined that petitioner
received interest income of $18. Respondent disallowed a
charitable deduction of $1,826 for 1996. Respondent made various
adjustments to petitioner’s depreciation deductions related to
her rental activities. Further, respondent disallowed suspended
losses from previous years and losses generated in 1996 and 1997
as a result of the limitation under sec. 469.
Petitioner did not present evidence regarding these issues.
As a result, petitioner is deemed to have conceded the items.
Rules 142(a), 149(b); Burris v. Commissioner, T.C. Memo. 2001-49.
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