Anthony Teong-Chan Gaw as Transferee of Radcliffe Investment LTD. - Page 179

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            balance sheet and income statement for the year ended March 31,                                
            1986.  See Rybak v. Commissioner, 91 T.C. at 566 n.19.  Conse-                                 
            quently, we unconditionally admit that document into evidence and                              
            make it a part of the record in these cases.                                                   
                         4.    Annual Reports of Pioneer and                                               
                               Financial Statements of Multi-Credit                                        
                  Respondent objected in the stipulations on grounds of hear-                              
            say to the admission of certain documents that purport to be                                   
            Pioneer's annual reports for the years ended March 31, 1983,                                   
            March 31, 1984, March 31, 1985,51 and March 31, 1986, and Multi-                               
            Credit's financial statements for the years ended March 31, 1986,                              
            and March 31, 1987.  On brief, respondent does not restate those                               
            objections or advance any argument relating to them.  We there-                                
            fore presume that respondent has abandoned her evidentiary objec-                              
            tions to the admission into evidence of the documents that pur-                                
            port to be the annual reports of Pioneer and the financial                                     
            statements of Multi-Credit.  See Rybak v. Commissioner, 91 T.C.                                
            at 566 n.19.  Consequently, we unconditionally admit those                                     
            documents into evidence and make them a part of the record in                                  
            these cases.52                                                                                 


            51  Contrary to the parties' stipulation that Exhibit 15-O is                                  
            Pioneer's annual report for the year ended Mar. 31, 1985, we find                              
            that exhibit to be an incomplete copy of that annual report.  At                               
            a minimum, that exhibit lacks certain notes to the financial                                   
            statements of Pioneer and its subsidiaries that are referred to                                
            therein.                                                                                       
            52  We unconditionally admit Exhibit 15-O as an incomplete copy                                
                                                                            (continued...)                 




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