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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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