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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.
2(...continued)
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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