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rules, we will not admit them into evidence.50
3. Horbury Financial Statement
Respondent objected in the stipulations on grounds of hear-
say to the admission of Horbury's balance sheet and income state-
ment for the year ended March 31, 1986. On brief, respondent
does not restate that objection or advance any argument relating
to it. We therefore presume that respondent has abandoned her
evidentiary objection to the admission into evidence of Horbury's
50 Even if we were to conclude that the documents in question
were not hearsay as petitioner contends, we would not necessarily
admit them into evidence. This is because those documents appear
to be merely cumulative of evidence already in the record. See
Fed. R. Evid. 403. The parties stipulated that (1) one share of
the stock of Traveluck was held in the name of Mme. Koo at all
relevant periods after Jan. 3, 1985; (2) one share of the stock
of Double Wealth was held in the name of Mme. Koo from Jan. 8,
1985, through the remainder of the years at issue; and (3) one
share of the stock of Forward was issued in the name of Mme. Koo
in December 1980. The beliefs of the persons signing the instru-
ments of transfer with respect to Traveluck, Double Wealth, and
Forward and the stock certificates of Traveluck and Forward
appear to add nothing to, and seem to be merely cumulative of,
those stipulations.
Moreover, even if we were to admit the documents in question
into evidence, they would not necessarily establish who owned a
majority of the stock of, or who controlled, Traveluck, Double
Wealth, or Forward; nor would they change our resolution of the
issues in these cases. Each instrument of transfer purports to
effect the transfer to or by, or the issuance to, Mme. Koo of
only one share of stock in each of those corporations, and the
respective stock certificates purport to certify ownership by
Mme. Koo of only one share of stock in Traveluck and in Forward.
No instrument of transfer indicated the number of issued and
outstanding shares of stock of the corporation to which it
relates. Although each stock certificate indicated the number of
authorized shares of stock of the corporation to which it re-
lates, there is no evidence in the record concerning the total
number of authorized shares of stock of each corporation that was
issued and outstanding during the years at issue.
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