-2-
1. Whether the notice of deficiency is “arbitrary”. We
hold it is not.
2. Whether petitioner may deduct a forgiven debt in the
amount claimed on his 1995 tax return. We hold he may.
3. Whether petitioner was personally engaged in the trade
or business of developing industrial real estate. We hold he
was.
4. Whether petitioner may under section 162 deduct certain
legal expenses paid by him.2 We hold he may.
5. Whether petitioner may under section 162 or 212 deduct
certain office expenses paid by him. We hold he may not.
FINDINGS OF FACT
Some facts were stipulated. The stipulated facts and the
accompanying exhibits are incorporated herein by this reference.
We find the stipulated facts accordingly. Petitioner resided in
Rochester Hills, Michigan, when the petition was filed.
1(...continued)
Petitioner failed to advance any arguments as to this issue in
his brief. Accordingly, we deem the issue abandoned. Wilcox v.
Commissioner, 848 F.2d 1007, 1008 n.2 (9th Cir. 1988), affg. T.C.
Memo. 1987-225; Lunsford v. Commissioner, 117 T.C. 183, 187
(2001); Nicklaus v. Commissioner, 117 T.C. 117, 120 n.4 (2001).
2 Unless otherwise stated, section references are to the
applicable versions of the Internal Revenue Code, Rule references
are to the Tax Court Rules of Practice and Procedure, and dollar
amounts are rounded to the nearest dollar.
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