Anthony Teong-Chan Gaw as Transferee of Radcliffe Investment LTD. - Page 178

                                                 - 76 -                                                    
            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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