Robert P. Sweet and Dawnielle K. Lawson - Page 3

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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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