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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.
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