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FINDINGS OF FACT1
Some facts are stipulated and are so found. The stipulation
of facts, with accompanying exhibits, is incorporated herein by
this reference.
Residence
At the time the petition was filed, petitioners resided in
Houston, Texas.
Medico Medical Services, Inc.
In 2000, petitioner husband (Mr. Oria) was the president and
sole shareholder of Medico Medical Services, Inc. (Medico). He
signed all of Medico’s checks issued in 2000 and generally
1 In part, Rule 151 provides as follows:
RULE 151. BRIEFS
* * * * * * *
(e) Form and Content: * * *
* * * * * * *
(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, showing the numbers of the statements to which
the objections are directed; in addition, the party may
set forth alternative proposed findings of fact.
Petitioners have filed an answering brief, but they
have failed therein to set forth objections to the proposed
findings of fact made by respondent. Accordingly, we must
conclude that petitioners have conceded respondent’s proposed
findings of fact as correct except to the extent that respondent
has failed to direct us to any evidence in the record supporting
those proposed findings or those findings are clearly
inconsistent with either evidence in the record or petitioners’
proposed findings of fact. See, e.g., Jonson v. Commissioner,
118 T.C. 106, 108 n.4 (2002), affd. 353 F.3d 1181 (10th Cir.
2003).
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Last modified: November 10, 2007