Anthony Teong-Chan Gaw as Transferee of Radcliffe Investment LTD. - Page 174

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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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