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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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