- 164 - 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”.Page: Previous 154 155 156 157 158 159 160 161 162 163 164 165 166 167 168 169 170 171 172 173 Next
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