Carolyn M. Fankhanel - Page 3

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          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...)           



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