Laurel Ann Curtis - Page 9

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          Facts”, is a narrative concerning certain portions of                       
          petitioner’s life, with particular reference to income tax                  
          difficulties.  It does not relate to the evidence in this case;             
          it contains no references to the transcript, exhibits, or other             
          sources relied upon to support statements.  It does not address             
          ownership of the real estate in question.  The second section,              
          “Proposed Findings of Fact”, contains no proposed findings, but             
          contains petitioner’s proposals for the Court to take particular            
          actions and for the Court to accept her arguments concerning the            
          law.  Attached to petitioner’s brief are various exhibits,                  
          including exhibits that appear to be attempts at affidavits                 
          addressing ownership of certain real estate.  Those exhibits are            
          not evidence, and we shall not consider them.                               
               Petitioner testified that the deficiencies in question were            
          attributable to real estate rents from property that she no                 
          longer owned.  Petitioner offered no corrobative evidence, either           
          testimonial or written, to support that assertion.  Indeed, she             
          failed even to identify the properties in question.  Given                  
          petitioner’s failure to corroborate her assertions, we need not,            
          and decline to, take them at face value.  See, e.g., Day v.                 

               exhibits or other sources relied upon to support the                   
               statement.  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.                       

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