Tracy P. Streber, F.K.A. Tracy C. Parker, et al. - Page 7

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               At the time the petitions in these cases were filed, the               
          residence of the Parkers was in Houston, Texas, and the                     
          residences of Tracy, Teresa, and Davis were in Austin, Texas.               
          Family Background                                                           
               Parker married Betty Parker (Betty) during 1958, and they              
          were divorced on March 12, 1982.  Tracy and Teresa are the                  
          daughters of Parker and Betty.  Tracy was born in 1965, and                 
          Teresa was born in 1960.  Parker, Betty, and the daughters lived            
          in California during the 1960's and early 1970's.  In 1972, they            
          moved to Houston, Texas, where Parker continues to reside.  In              
          1983, following his divorce from Betty, Parker married Martha.              

          3 (...continued)                                                            
                    (3)  * * *  In an answering or reply brief, the                   
               party shall set forth any objections, together with the                
               reasons therefor, to any proposed findings of any other                
               party, showing the numbers of the statements to which                  
               the objections are directed; in addition, the party may                
               set forth alternative proposed findings of fact.                       
               In the instant case, respondent, the Parkers, and the                  
          daughters filed simultaneous opening and reply briefs.  The                 
          daughters' reply brief contains objections to the Parker’s                  
          proposed findings but does not contain any objections to                    
          respondent's proposed findings.  Accordingly, we must conclude              
          that the daughters have conceded respondent's proposed findings             
          of fact as correct except to the extent that the daughters’                 
          proposed findings are clearly inconsistent therewith.  See Fein             
          v. Commissioner, T.C. Memo. 1994-370 n.1; Estate of Stimson v.              
          Commissioner, T.C. Memo. 1992-242; Cunningham v. Commissioner,              
          T.C. Memo. 1989-260 n.6.                                                    

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