- 2 - treated as precedent for any other case. Unless otherwise indicated, subsequent 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. Respondent determined deficiencies of $6,391, $4,838 and $3,479 in petitioners’ 2002, 2003, and 2004 Federal income tax, respectively. Respondent also determined that petitioners are liable for accuracy-related penalties under section 6662(a) of $1,278.20 for 2002, $967.60 for 2003, and $18 for 2004. Respondent concedes that the adjustment to petitioners’ gross receipts for 2002 reported on Schedule C, Profit or Loss From Business, should be $11,169. Respondent also concedes that for 2003, the Schedule C depreciation adjustment should be $8,504; and for 2004 the Schedule C adjustments should be $5,843 for “other expenses” and $995 for depreciation, the self- employment tax is $303, and the self-employment tax deduction is $152. Petitioners concede as correct the adjustment for rent/lease of business property for 2002 and the adjustments to Schedule F, Profit or Loss From Farming, for 2002 and 2003. Petitioners presented no evidence or argument with respect to respondent’s adjustments to itemized deductions for 2002, 2003, and 2004. The Court therefore deems the latter adjustments to have been conceded by petitioners. See Rule 149(b); Rothstein v.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008