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(15) whether petitioners are liable for accuracy-related
penalties under section 6662(a) and (b)(2) for 1989, 1990, and
1993 because of substantial understatements of their income tax.
FINDINGS OF FACT3
Some of the facts have been stipulated and are so found.
The stipulation of facts filed by the parties is incorporated in
this opinion by this reference.
Background
Petitioners resided in Rapid City, South Dakota, when they
filed their petition. Hereinafter, references to petitioner are
to Richard Haeder, and references to Mrs. Haeder are
to Judith Haeder. For each of the years in issue, petitioners
claimed dependency exemptions for two minor children.
After completing a clerkship in Washington, D.C., petitioner
had started working for a large law firm located in Portland,
Oregon, in 1967. During the years at issue, petitioner was an
attorney licensed to practice law in the States of Oregon and
3Contrary to Rule 151(e), which governs the form and content
of briefs submitted to the Tax Court, petitioners provided in
their opening brief a “statement of facts” that was not presented
in numbered statements and that, for the most part, did not give
references to the pages of the transcript, exhibits, or other
sources relied upon to support the statements contained therein.
Furthermore, in their reply brief, petitioners did not set forth
objections to respondent’s proposed findings of fact.
Consequently, in our findings of fact, we have relied heavily
upon respondent’s proposed findings. By failing to follow the
Court’s Rules, “petitioners have assumed the risk that we have
not considered the record in a light of their own illumination.”
Monico v. Commissioner, T.C. Memo. 1998-10.
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