- 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”.
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