- 28 -
They are not the result of mistake, undue influence, fraud, or
duress.
We conclude on the basis of the foregoing that the self-
canceling clauses must be given effect, and that the value of
each of the 1999 notes is $1,687,704 as determined by
respondent.19 To reflect the foregoing,
Decision will be
entered under Rule 155.
19 In the opening brief, respondent contended that the
share adjustment clauses are void because they are against public
policy. Petitioner did not respond to respondent’s argument.
We deem this issue conceded because petitioner made no argument
about it on brief. See Chevron Corp. v. Commissioner, 104 T.C.
719, 758 (1995); Remuzzi v. Commissioner, T.C. Memo. 1988-8,
affd. without published opinion 867 F.2d 609 (4th Cir. 1989).
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