- 2 -
Court considers petitioner to have conceded respondent's
determinations disallowing amounts of itemized deductions in both
years and "other expenses" in 1997 because petitioner did not
address these issues at trial or on brief. See Bradley v.
Commissioner, 100 T.C. 367, 370 (1993); Sundstrand Corp. v.
Commissioner, 96 T.C. 226, 344 (1991); Rybak v. Commissioner, 91
T.C. 524, 566 n.19 (1988).
In his opening statement, petitioner alleged that
respondent's statutory notice is so vague as to deprive
petitioner of proper notice or the Court of jurisdiction. Upon
questioning by the Court, petitioner cited no basis for his
position but represented that he would brief the issue. He did
not, and the Court finds that petitioner has abandoned this
issue. See Bradley v. Commissioner, supra; Sundstrand Corp. v.
Commissioner, supra; Rybak v. Commissioner, supra.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years at issue.
The stipulated facts and exhibits received into evidence are
incorporated herein by reference. At the time the petition in
this case was filed, petitioner resided in Cedar Park, Texas.
FINDINGS OF FACT
For 20 years petitioner's mother, Rhoda Colvin, resided in a
unit of a condominium development known as Pennant Village (PV),
in San Diego, California. Her address at the condominium was
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011