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deemed admitted by petitioner pursuant to Rule 90; those matters
also are incorporated herein by this reference.
Petition
At the time petitioner filed the petition in this case, she
resided in Bristol, West Virginia.
Failure to File
Petitioner failed to file Federal income tax returns for the
11 taxable (calendar) years in issue (1983 through 1993).
Introduction to Petitioner’s Income Producing Activities
Petitioner lived in Colorado from 1978 until November 1989,
when she moved to Florida. Petitioner obtained a Colorado real
estate salesperson’s license in 1978 and worked for various real
estate agents in Colorado from then until 1984, when she obtained
a Colorado real estate broker’s license. She then formed her own
real estate company, Fankhanel and Associates, which employed two
to four persons and provided petitioner with an income until she
left Colorado in 1989. During the time she lived in Colorado,
petitioner also owned several pieces of rental real estate,
engaged in real estate development, and was a partner in a plant
store. Petitioner sold her Colorado real properties when she
left Colorado.
1(...continued)
Accordingly, we must conclude that petitioner has conceded
respondent’s proposed findings of fact as correct except to the
extent that petitioner’s opening brief contains proposed findings
clearly inconsistent therewith. See, e.g., Estate of Freeman v.
Commissioner, T.C. Memo. 1996-372.
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