Evert E. and Eva F. Berglund - Page 10

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            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.                                                                                     







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