Gregory Charles Carlo - Page 6

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               The petition in the instant case did not contain any                   
          specific allegations regarding any of the three additions to tax            
          or facts to support any such allegations.  Therefore, these                 
          issues are all deemed conceded by petitioner, and respondent has            
          no burden of production under section 7491(c).  See Funk v.                 
          Commissioner, supra; Swain v. Commissioner, 118 T.C. 358, 363-364           
          (2002).                                                                     
               Accordingly, respondent’s motion to dismiss for failure                
          properly to prosecute will be granted.                                      
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                        under Rule 155.                               
                                                                                     
























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