Alex and Tonja Oria - Page 3

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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.                                                             
               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.                

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