- 50 - unsubstantiated bad debts for the taxable year. Respondent concedes this adjustment. 3. Respondent disallowed $140,873 of petitioner’s reported interest expense deduction for 1993 to reflect unsubstantiated interest expenses for the taxable year. Petitioner concedes that adjustment, to the extent of $142,214. a. As a mathematical computation, petitioner’s concession is in excess of that which respondent determined was unsubstantiated. The parties stipulated, however, that $19,105 is properly at issue. b. Respondent concedes that portion of the $19,105 paid which constitutes a safe-haven rate of interest calculated, pursuant to sec. 482 and the regulations thereunder, on the underlying loan, to the extent that portion exceeds the amount paid on that underlying loan already allowed as an interest expense on the underlying loan ($895). 4. Petitioner claimed a net operating loss for 1994 and carried a loss back to 1993. Petitioner concedes it was not entitled to claim a net operating loss in 1994 or carry a loss back to 1993. 5. Respondent recomputed petitioner’s environmental tax and environmental tax deduction. Petitioner presented no argument regarding this recomputation, and we deem petitioner to have conceded this adjustment. 6. Respondent determined petitioner was liable for a civil fraud penalty for 1993 in the amount of $13,428 pursuant to sec. 6663. Respondent concedes that determination. 7. Respondent determined petitioner was liable for a penalty for 1993 pursuant to sec. 6662(a) for substantial understatement of tax. Petitioner presented no argument regarding the penalty. We deem petitioner to have conceded the application of the penalty. III. Docket No. 20254-94, June Cordes: A. 1989: 1. Respondent determined petitioner was allowed a deduction for 1989 for a personal exemption in the amount of $2,000. Petitioner did not dispute this determination, and we deem petitioner to have conceded this adjustment.Page: Previous 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 Next
Last modified: May 25, 2011