James Tinnell - Page 3

                                        - 3 -                                         
                                  FINDINGS OF FACT4                                   
               The parties have stipulated some of the facts, which we                
          incorporate in our findings by this reference.  Petitioner was a            
          resident of Las Vegas, Nevada, when the petition in this case was           
               Petitioner graduated from the University of Arkansas School            
          of Medicine in 1962.  In 1965, petitioner began practicing                  
          medicine in Lewisburg, Tennessee.  Five years later, petitioner             
          relocated his medical practice to Chattanooga, Tennessee.                   
          Petitioner has been engaged in the practice of medicine at all              
          relevant times.                                                             
          I.   Delta Roofing Mills                                                    
               In or about 1973, petitioner and his father purchased Delta            
          Roofing Mills, a roofing manufacturing business in Slidell,                 
          Louisiana, for approximately $1 million.  Petitioner participated           
          in the management and marketing of Delta Roofing Mills, which               
          tripled its gross sales while petitioner and his father owned it.           
          Five years after petitioner and his father purchased Delta                  
          Roofing Mills, they sold it to Republic Gypsum Corp. for                    
          approximately $3 million and split the net sale proceeds.                   

               4In his opening brief, petitioner set forth “Proposed                  
          Findings of Fact” that were in essence ultimate findings of fact.           
          By neglecting to follow Rule 151(e), which requires petitioner to           
          include numbered proposed findings of fact, petitioner has                  
          “assumed the risk that we have not considered the record in a               
          light of * * * [his] own illumination.”  Monico v. Commissioner,            
          T.C. Memo. 1998-10.                                                         

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011