W. Bradford Davis and Tedde M. Rinker - Page 3

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               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  At the time they filed              
          their petition, petitioners resided in California.                          
               For convenience, we have consolidated our findings of fact             
          and opinion.                                                                
               During 1999, petitioners were married.  In 1999, Dr. Rinker            
          carried on a medical practice in Burlingame, California.  During            
          1999, W. Bradford Davis (Mr. Davis) worked for three employers,             
          earning $104,583 in wages.  At some point in 1999, Mr. Davis                
          ended his employment with the last of those three employers, a              
          company called Wind River, and was not employed by another                  
          concern for the rest of the year.  Mr. Davis and Dr. Rinker have            
          since divorced.                                                             
          I.  Deemed Admissions                                                       
               On December 13, 2004, respondent served requests for                   
          admission on Mr. Davis and Dr. Rinker.  Respondent filed the                
          requests with the Court on December 14, 2004.  The requests asked           
          petitioners to admit two facts:  (1) That Mr. Davis’s 1999                  
          photography activity was not entered into for profit, and (2)               
          that the gross receipts of Dr. Rinker’s medical practice were               
          $120,531 in 1999.                                                           









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