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that will support a finding that the matter in question is what
the proponent claims is sufficient to authenticate that evidence.
Fed. R. Evid. Rule 901(b)(1). With respect to Petitioner's
Exhibits 5 and 6, we believe respondent's objection goes to the
weight of the evidence rather than its admissibility, and we
overrule the objection. As for Petitioner's Exhibit 8,
petitioner's testimony that he owns the Gibraltar property is
sufficient to provide the foundation necessary for this Court to
draw the inference that the evidence is what it is claimed to be.
Respondent's objection to these exhibits based on authenticity
is overruled.
We also overrule respondent's hearsay objection to
Petitioner's Exhibit 8. The hearsay is defined as "a statement,
other than one made by the declarant while testifying at the
trial or hearing, offered in evidence to prove the truth of the
matter asserted." Fed. R. Evid. Rule 801(c). Normally, hearsay
is excluded from evidence unless an exception to the hearsay rule
applies. Snyder v. Commissioner, 93 T.C. 529, 532 (1989). This
rule is designed to avoid the introduction of evidence that may
have the appearance of trustworthiness, but is not subject to the
test of cross-examination. Anderson v. United States, 417 U.S.
211, 220 (1974); Snyder v. Commissioner, supra at 533. Business
records are excepted from this exclusion, and we believe the
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