- 2 - Respondent determined for the year 2000 a deficiency in petitioners' Federal income tax of $5,437 and an accuracy-related penalty of $1,087. The Court considers petitioners to have conceded respondent's determination disallowing itemized deductions of $540 because petitioners provided neither argument nor evidence on the issue at trial. 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). Petitioners concede that respondent correctly determined that $1,283 of respondent's $17,986 adjustment in the statutory notice of deficiency is a passive activity loss. The issues remaining for decision are whether for 2000 petitioners: (1) Are entitled to deduct a loss of $16,703 on Schedule E, Supplemental Income and Loss; and (2) whether petitioners are liable for the accuracy-related penalty under section 6662. Some of the facts have been stipulated and are so found. The stipulation of facts and exhibits received in evidence are incorporated herein by reference. At the time the petition was filed, petitioners resided in Noblesville, Indiana. Background Robert P. Sweet (petitioner) was employed during the year as a real estate loan officer, and his wife, Dawnielle K. Lawson, was not employed outside of the home.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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