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Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
At trial, petitioner stated that she was contesting only
some of the business expense deductions respondent disallowed for
1999 and 2000. At trial, petitioner did not dispute the amounts
of unreported gross income, the self-employment tax, the addition
to tax, or the penalties determined by respondent. Although
ordered to do so, petitioner did not file any briefs.
Accordingly, petitioner has abandoned all issues other than
whether she substantiated business expenses in excess of the
amounts allowed or conceded by respondent for 1999 and 2000.1
Petzoldt v. Commissioner, 92 T.C. 661, 683 (1989); Money v.
Commissioner, 89 T.C. 46, 48 (1987); cf. Funk v. Commissioner,
123 T.C. 213 (2004); Swain v. Commissioner, 118 T.C. 358 (2002).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time she filed the
petition, petitioner resided in Largo, Florida.
1 We note that on brief respondent also conceded $612 of
unreported income for 2000. This concession will be accounted
for in the Rule 155 computation.
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