- 3 - deductions on account of rental real estate related expenditures, and (7) the additions to tax apply. On our own motion, we also decide that petitioner must pay a penalty under section 6673(a)(1) on account of proceedings instituted primarily for delay and for taking groundless positions. Unless otherwise noted, all 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. FINDINGS OF FACT Introduction The parties failed to stipulate any facts. They have, however, stipulated to certain exhibits, and those exhibits are incorporated herein by this reference.1 Certain matters are 1 In part, Rule 151 provides as follows: RULE 151. BRIEFS * * * * * * * (e) Form and Content: * * * * * * * * * * (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. Petitioner failed to file an answering brief. Because petitioner failed to file an answering brief, petitioner failed to object to any of respondent’s proposed findings of fact. (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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