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FINDINGS OF FACT2
The parties have stipulated some facts, which we incorporate
herein. When they filed their petition, petitioners resided in
Rockdale, Texas.
Petitioner John R. Rinn (Mr. Rinn) is a dentist. During
1995 through 2000, he owned a dental practice. Petitioner
Donnie J. Rinn (Mrs. Rinn) was office manager and primary
bookkeeper for Mr. Rinn’s dental practice.
During 1995 through 2000, Mr. Rinn earned substantial income
from his dental practice, as shown below:
Allowable
Gross Business Allowable Net
Year Receipts Expenses Depreciation Profit
1995 $303,125 $157,438 $630 $145,057
1996 344,113 214,045 630 129,438
1997 335,592 206,944 630 128,018
1998 343,081 155,382 630 187,069
1999 397,578 267,672 630 129,276
2000 261,346 170,149 630 90,567
For tax years 1995 through 2000, petitioners filed no
Federal income tax returns and paid no taxes on any income from
2 Petitioners failed to file any posttrial brief and
consequently failed to set forth any objections to respondent’s
proposed findings of fact. We consider petitioners to have
waived any objections to respondent’s proposed findings of fact.
See Rule 151(e)(3) (“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”). We have
adopted respondent’s proposed findings of fact, insofar as they
are supported by the record.
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