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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.]
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