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returns for 1984, 1985, and 1986. On brief, he does not restate
that objection or advance any argument relating to it. We
therefore presume that petitioner has abandoned his evidentiary
objection to the admission into evidence of his individual
Federal income tax returns for 1984, 1985, and 1986. See Rybak
v. Commissioner, 91 T.C. 524, 566 n.19 (1988). Consequently, we
unconditionally admit those returns into evidence and make them a
part of the record in these cases.
2. Certain Instruments of Transfer
and Stock Certificates
Respondent objected in the stipulations on grounds of
hearsay to the admission of certain instruments of transfer with
respect to Traveluck, Double Wealth, and Forward, and certain
stock certificates with respect to Traveluck and Forward. On
brief, respondent restates those objections.
To counter respondent's hearsay objections, petitioner
appears to argue that the documents in question are not excludi-
ble hearsay under rule 802 of the Federal Rules of Evidence
because he is not offering them for the truth of the matters
asserted therein, but to show that the persons signing those
documents believed that Mme. Koo was a shareholder of those
corporations.
Rule 801(c) of the Federal Rules of Evidence defines hearsay
as "a statement, other than one made by the declarant while
testifying at the trial or hearing, offered in evidence to prove
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