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Respondent determined unreported income from real estate
that petitioner concedes she once owned, but claims she no longer
owns. Petitioner cannot credibly maintain that she does not know
what real estate respondent has in mind. Moreover, ownership of
real estate is a matter that is commonly proved in courts of law.
Indeed, attached as exhibits to petitioner’s brief are affidavits
that petitioner claims prove just that issue. Petitioner has the
burden to prove that she no longer owns the real estate in
question. Petitioner, however, has failed to carry that burden.
C. Ownership of Real Estate
In the petition, petitioner avers nothing with respect to
the ownership of any real estate. Petitioner’s brief contains
sections titled “Petitioner’s Sworn Statement of Facts” and
“Proposed Findings of Fact”. Neither section, if intended to be
petitioner’s proposed findings of fact, complies with Rule
151(e)(3).2 The first section, “Petitioner’s Sworn Statements of
2 Rule 151(e)(3) provides:
(e) Form and Content: All briefs shall contain
the following in the order indicated:
* * * * * * *
(3) Proposed findings of fact (in the opening
brief or briefs), based on the evidence, in the form of
numbered statements, each of which shall be complete
and shall consist of a concise statement of essential
fact and not a recital of testimony nor a discussion or
argument relating to the evidence or the law. In each
such numbered statement, there shall be inserted
references to the pages of the transcript or the
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