Nathan P. and Geraldine V. Morton - Page 9

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             essentially indistinguishable from the events which were                 
             determined to be relevant in Estate of Jung v.                           
             Commissioner, supra.                                                     
                  We also find that the documents in question do not                  
             create an undue risk of prejudice or confusion of the                    
             issues.  A court may exclude relevant evidence if "its                   
             probative value is substantially outweighed by the danger                
             of unfair prejudice, confusion of the issues, or misleading              
             the jury, or by considerations of undue delay, waste of                  
             time, or needless presentation of cumulative evidence."                  
             Fed. R. Evid. 403.  Petitioners do not point to any                      
             specific facts which indicate that the evidence at issue                 
             would create an undue risk of prejudice or confusion of the              
             issues if admitted.  Rather, petitioners merely state that               
             "Respondent's documents would unduly prejudice Petitioners               
             and confuse the issues and should not be considered by this              
             Court in determining the value of the subject stock."  We                
             find petitioners' conclusory statement in this regard both               
             unsupported and unpersuasive.  The documents at issue are                
             highly probative and do not, in our estimation, create an                
             undue risk of prejudice or confusion of the issues.                      
             Accordingly, we shall grant respondent's motion in limine                
             and overrule petitioners' objections to the admission of                 
             the first four items listed above into evidence.  We shall               
             overrule respondent's motion in limine and sustain                       




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