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Financial) stock in 1987 was taken in the wrong year is new
matter on which respondent bears the burden of proof. We hold
that it is.
2. Whether testimony in the trial of this case by Federal
Bureau of Investigation (FBI) special agents is a record or
report of a public agency, admissible under rule 803(8) or (24)
of the Federal Rules of Evidence. We hold that it is not.
3. Whether 264 pages of interview notes made by FBI
special agents which were not exchanged before trial are
admissible. We hold that they are not.
4. Whether petitioners may deduct $727,600 for a loss from
Dondi Financial stock in 1987. We hold that they may.
5. Whether petitioners may deduct $199,600 for a loss from
Texana Capital Corp. stock in 1988. We hold that they may.
Section references are to the Internal Revenue Code in
effect for the years in issue. Rule references are to the Tax
Court Rules of Practice and Procedure unless otherwise stated.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioners
Petitioners are married and lived in Scottsdale, Arizona,
when they filed their petition.
Richard A. Little (petitioner) graduated from the University
of Michigan in 1957 with a bachelor's degree in economics.
Petitioner was an officer in the U.S. Air Force. He was
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