I-Tech R&D Limited Partnership - Page 3




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                                  FINDINGS OF FACT4                                   
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts, second stipulation of facts, and the              
          attached exhibits are incorporated herein by this reference.                
               I-Tech was organized as a Maryland limited partnership in              
          1984 with three general partners: (1) Professor Itzhak Yaakov,5             
          (2) Capital Corp. of Washington (Capital),6 and (3) Lloyd Levin.            
          Capital7 is owned by Robert Slavitt.                                        
               Mr. Yaakov served in the Israel Defense Forces (IDF) for               


               3(...continued)                                                        
          not address this issue in either his original or reply briefs, we           
          consider it to have been conceded.  See Remuzzi v.  Commissioner,           
          T.C. Memo. 1988-8, affd. 867 F.2d 609 (4th Cir. 1989).                      
               4Petitioner has ignored Rule 151(e)(3), which provides, in             
          part:                                                                       
               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.                           
               Under the circumstances, we have assumed that petitioner               
          does not object to respondent’s proposed findings of fact except            
          to the extent that petitioner’s statements on brief are clearly             
          inconsistent therewith, in which event, we have resolved the                
          inconsistencies based on our understanding of the record as a               
          whole.  See Gleave v. Commissioner, T.C. Memo. 1997-276, n.3; see           
          also Estate of Jung v. Commissioner, 101 T.C. 412, 413 n.2                  
          (1993).                                                                     
               5The advisory general partner.                                         
               6The managing general partner.                                         
               7Capital is a District of Columbia corporation.                        





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