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After concessions,2 the issues for decision are: (1) How
much of an alimony deduction petitioner is entitled to for 1998;
(2) whether petitioner is entitled to claim dependency exemptions
for his children for 1998; (3) whether petitioner is entitled to
claim head of household filing status for 1998; (4) whether
petitioner is entitled to deduct any amount for unreimbursed
employee business expenses for 1998; and (5) whether petitioner
is liable for the addition to tax pursuant to section 6651(a)(1)
for 1998.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
2 Mr. Maher stipulated that he received income in excess of
the amount determined by respondent. Respondent stipulated that
Mr. Maher had total prepaid Federal income tax credits of
$20,894, paid $12,698 in State and local income taxes, and made
$400 in charitable contributions for 1998. Respondent conceded
that Mr. Maher is entitled to an alimony deduction consisting of
one-half of the mortgage payments (principal and interest) he
paid, one-half of the real estate taxes he paid, one-half of the
homeowners insurance he can prove he paid, and the health and
automobile insurance he can prove he paid on behalf of his wife.
Respondent conceded that Mr. Maher is entitled to deduct as an
itemized deduction the other half of the mortgage interest and
real estate taxes paid.
At trial and on brief, Mr. Maher did not address the
additions to tax pursuant to secs. 6651(a)(2) and 6654(a).
Therefore, we find that Mr. Maher abandoned these issues. See
Petzoldt v. Commissioner, 92 T.C. 661, 683 (1989); Money v.
Commissioner, 89 T.C. 46, 48 (1987).
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