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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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