Walter L. Medlin - Page 81

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                                     Appendix C                                       
                                    CONCESSIONS100                                    

                             SCHEDULE C MISCELLANEOUS INCOME                          

                           Taxable Year                                               
                                        1985      1986      1987      1988            
          Notice of deficiency                                                        
               Miscellaneous income$12,357     $27,019     $73,907     $24,000        
          Amounts conceded by petitioner                                              
               Commission Income   $6,357      $3,019       - 0 -       - 0 -         
               Rent                    6,000      24,000     $24,000     $12,000      
          Total                    12,357      27,019      24,000      12,000         
          Amounts conceded by respondent                                              
               Forgiveness of debt - 0 -       - 0 -     $49,907*       $0            
          Amounts in dispute                                                          
               Rent                     - 0 -       - 0 -       - 0 -     $12,000     
          *Respondent concedes his forgiveness of debt determination for 1987.  However,
          he raises as new matter that petitioner realized $112,156 of ordinary income
          from the sale by foreclosure of the Citrus County Property in 1985.  See    
          appendix B.                                                                 












               100Respondent prepared on brief a reconciliation of items              
          which are “in dispute” and concessions as to the adjustments in             
          the statutory notice of deficiency.  Appendix C of this opinion             
          reflects the reconciliation schedules that respondent prepared              
          and which petitioner stipulated in his answering brief.  However,           
          there are a number of income items, as we discuss in the opinion,           
          that the parties represented were still in dispute but which                
          petitioner does not contest on brief.  Instead, he states:  “In             
          addition, any issues not raised in Petitioner’s Brief are also              
          conceded by Petitioner”.                                                    


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