Richard A. and Carol B. Little - Page 2

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               reports of a public agency admissible under Fed. R.                    
               Evid. 803(8) or (24).                                                  
                    Held:  R's contention in the amended answer is                    
               new matter upon which R bears the burden of proof.                     
               Rule 142(a), Tax Court Rules of Practice and Procedure.                
                    Held, further, oral testimony of the two FBI                      
               agents is not a record or report of a public agency of                 
               Fed. R. Evid. 803(8).                                                  
                    Held, further, oral testimony of the two FBI                      
               agents is not admissible under Fed. R. Evid. 803(24)                   
               because respondent did not satisfy the notice                          
               requirement of the rule.                                               
                    Held, further, the interview notes are not                        
               admissible because they were not exchanged before trial                
               contrary to the Court’s standing pretrial order.                       
                    Held, further, P may deduct $727,600 for DF stock                 
               in 1987.                                                               
                    Held, further, P may deduct $199,600 for T stock                  
               in 1988.                                                               


               John D. Copeland, for petitioners.                                     
               Steven Walker and Barbara Leonard, for respondent.                     


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               COLVIN, Judge:  Respondent determined that petitioners had             
          deficiencies in Federal income tax of $162,761 for 1987 and                 
          $57,199 for 1988.  Respondent filed an amended answer asserting             
          an additional deficiency of $31,170 for 1987.                               
               The issues for decision are:                                           
               1.   Whether respondent's contention that petitioners'                 
          worthless stock deduction for Dondi Financial Corp. (Dondi                  





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