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(1) Whether petitioner received unreported income from the
sale of tax shelters and insurance during 1982, 1983, 1984, 1985,
1986, and 1987 of $56,701, $46,744, $16,939, $27,783, $49,346,
and $23,406, respectively;
(2) whether petitioner is entitled to various deductions
claimed on Schedule C, Profit or Loss from Business, in addition
to those allowed by respondent for all years at issue;
(3) whether petitioner is entitled to claim dependency
exemptions under section 151 for his two children2 for 1982 and
1986;3 and
(4) whether petitioner is liable for additions to tax for
fraud pursuant to section 6653(b)(1) and (2) for 1982 through
1(...continued)
issue; and (4) is liable for additions to tax pursuant to sec.
6654 for failure to make estimated tax payments for all years at
issue. Because petitioner failed to address these issues at
trial or on brief, we deem these issues conceded. See Rule
151(e)(4) and (5); Petzoldt v. Commissioner, 92 T.C. 661, 683
(1989); Money v. Commissioner, 89 T.C. 46, 48 (1987).
Petitioner conceded in the stipulation of facts that he
received taxable income from: (1) Wages during 1982 and 1983 of
$4,549 and $165, respectively; (2) partnership distributions
during 1983 and 1984 of $4,834 and $3,416, respectively; and (3)
dividends during 1984 and 1985 of $25,773 and $46,884,
respectively.
2In his petition, petitioner asserted that he was entitled
to dependency exemptions for three children for the years at
issue. The record indicates that petitioner has only two
children.
3In the notice of deficiency, respondent allowed dependency
exemptions for two of petitioner’s children during 1983, 1984,
1985, and 1987.
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