Anthony Teong-Chan Gaw as Transferee of Radcliffe Investment LTD. - Page 185

                                                 - 83 -                                                    
            On the instant record, we conclude that the newspaper article is                               
            not admissible under that rule.56                                                              
                         6.    August 28, 1987 Memorandum                                                  
                  Respondent objected in the stipulations on grounds of rele-                              
            vance and hearsay to the admission of a memorandum dated August                                
            28, 1987 (August 1987 memorandum), from Thomas D. Fuller, then                                 
            Special Assistant to the Associate Chief Counsel (International),                              
            to the Director of Public Affairs that accompanied copies of Rev.                              
            Rul. 87-89, 1987-2 C.B. 195, for release under the Service's                                   
            advance revenue ruling procedures.  On brief, respondent restates                              
            those objections.57                                                                            
                  To counter respondent's relevancy objection, petitioner                                  
            appears to contend that the August 1987 memorandum is relevant to                              
            petitioner's constitutional and abuse of discretion claims.  To                                
            counter respondent's hearsay objection, petitioner argues that                                 
            that memorandum is admissible under rules 803(8) and 803(24) of                                
            the Federal Rules of Evidence to show that the form of financing                               
            analyzed in Rev. Rul. 87-89, supra, was popular at the time the                                
            ruling was issued and under rules 801 and 803(3) of the Federal                                
            Rules of Evidence to show that the Service's National Office                                   


            56  Even if we were to admit the newspaper article into evidence,                              
            it would not change our resolution of petitioner's constitutional                              
            and abuse of discretion claims in these cases.                                                 
            57  The August 1987 memorandum stated in relevant part that Rev.                               
            Rul. 87-89, supra, provides guidance with respect to "currently                                
            popular international financing structures."                                                   




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