- 35 - On opening brief petitioner did not propose any findings of fact or present any argument regarding the business expense deductions. Petitioner evidently concluded that the business expense deduction disputes were not worth the necessary effort. In violation of the Court’s specific directions and explanation, neither of petitioner’s briefs includes proposed findings of fact, or objections to respondent’s proposed findings of fact, as to the business expense deduction disputes. However, on answering brief petitioner did include a short contention that it is entitled to a rent expense deduction “at a minimum * * * of 11(...continued) * * * * * * * (e) Form and Content: All briefs shall conform to the requirements of Rule 23 and shall contain the following in the order indicated: * * * * * * * (3) Proposed findings of fact (in the opening brief or briefs), based on the evidence, in the form of numbered statements, each of which shall be complete and shall consist of a concise statement of essential fact and not a recital of testimony nor a discussion or argument relating to the evidence or the law. In each such numbered statement, there shall be inserted references to the pages of the transcript or the 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. [Emphasis added.]Page: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Next
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