- 72 - 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 provePage: Previous 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 Next
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