- 2 - 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. (DondiPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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