- 10 - into signing various documents when they obtained their loans. Petitioner's brief contains the following prayer of relief: We beg and pray the courts will allow our real estate and property to be returned to us as of August 3, 1983 so our just bills can be paid. We enter a motion and petition that the First National Bank of Danville of Danville, Illinois and Trustee James R. Geekie are guilty of discrimination and price fixing our real estate and conversion of Federal funds. We enter a motion and petition of criminal conspiracy, for we are victimized in a fraudulent judgment scheme and corruption upon the courts and we ask for relief. Discussion Petitioner bears the burden of establishing that respondent's determination of deficiencies, as contained in the statutory notice of deficiency, is incorrect. Rule 142(a); Welch v. Helvering, 290 U.S. 111 (1933). Petitioner did not offer any testimony or documentary proof that the determinations of respondent in her statutory notice of deficiency, as modified by respondent's concessions and conditional concessions, are incorrect. Petitioner attached documents to his brief that had not been admitted into evidence when this case was accepted as a fully stipulated case on October 3, 1994. Statements in briefs do not constitute evidence. Rule 143(b). On October 3, 1994, the record of this case was closed. Accordingly, we hold that the exhibits received from petitioner that were not offered at trial are not admitted into evidence and are not a part of the record.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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