- 2 -
respectively, for 2000. Respondent also determined that
petitioner was liable for an addition to tax under section
6651(a)(2) in an amount to be determined. Petitioner seeks a
redetermination of the deficiency and additions to tax. After
concessions,2 the issues for decision are:
(1) Whether petitioner received unreported income in the
form of nonemployee compensation and an early individual
retirement account (IRA) distribution;
(2) whether petitioner is liable for an addition to tax
under section 6651(a)(1) for failing to file his 2000 tax return;
and
1(...continued)
Procedure.
2Respondent concedes that petitioner is not liable for the
addition to tax under sec. 6651(a)(2) and is liable for an
addition to tax under sec. 6654 in the reduced amount of
$2,538.56. Petitioner concedes that he received unreported wage
income of approximately $23,000 and that he did not file a
Federal income tax return for 2000.
Petitioner argued in his petition that the notice of
deficiency did not sufficiently describe the basis of the tax
deficiency as required by sec. 7522. However, he did not raise
this argument on brief, and, therefore, we deem it conceded. See
Rule 151(e)(4) and (5); Petzoldt v. Commissioner, 92 T.C. 661,
683 (1989). Petitioner also argued in his petition that he is
not liable for self-employment tax because he did not receive
self-employment income and that he is not liable for the
additional tax under sec. 72(t) on the early withdrawal of an
individual retirement account (IRA) distribution because he did
not have an IRA account nor did he receive an IRA distribution.
Because petitioner similarly failed to raise these issues on
brief, we also deem them conceded to the extent we decide
petitioner had unreported income in the form of nonemployee
compensation and an early IRA distribution during 2000. See Rule
151(e)(4) and (5); Petzoldt v. Commissioner, supra at 683.
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