Gary Lee Colvin - Page 2

                                        - 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