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After concessions,2 the issues for decision are:
(1) Whether petitioner should be relieved of deemed
admissions resulting from his failure to respond to respondent’s
requests for admission;
(2) whether petitioner is entitled under section 170 to
deduct certain charitable contributions for 1998, 1999, and 2000;
(3) whether petitioner received unreported income from
Registe Religious Society (hereinafter RRS) during 1999;
(4) whether petitioner is entitled to claim the child tax
credit for 1998 and 1999; and
2Petitioner did not contest the following adjustments in his
petition: (1) Disallowance of State and local tax deductions of
$119 and $413 for 1998 and 2000, respectively; and (2)
disallowance of interest deduction of $70 for 1998. Petitioner
did not present evidence to dispute these adjustments at trial or
arguments on these adjustments in his brief. These adjustments
are deemed conceded in accordance with Rule 34(b)(4). On May 12,
2004, the parties filed a stipulation of settled issues in which
respondent conceded that petitioner is entitled to dependency
exemptions for his daughters Shenara, Keturah, and Adara
Castleton for taxable years 1998 and 1999.
Respondent determined that petitioner was entitled to a
child tax credit of $1,500 for 2000. In the notice of deficiency
respondent adjusted petitioner’s child tax credit by $64 but
identified the year of the adjustment as 2000 on Form 4549A,
Income Tax Examination Changes, and as 1999 on Form 886-A,
Explanation of Items. For purposes of this opinion we assume
that this adjustment is computational and will be dealt with in
the Rule 155 computation.
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