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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
filed.
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.
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