David W. Chiu - Page 5

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            real estate taxes, $5,760 for home mortgage interest, and $2,568                             
            for charitable contributions, in addition to the previously                                  
            outlined Schedule C deductions totaling $2,618 and the deduction                             
            for moving expenses in the amount of $3,184.                                                 
                                                OPINION                                                  
                  There are two evidentiary matters we must address at the                               
            outset.  First are the objections raised by respondent in                                    
            paragraphs 4 and 5 of the stipulation of facts to the admission                              
            of Joint Exhibits 3-C and 4-D.  Joint Exhibit 3-C consists of a                              
            copy of a "Statement of AssetVantage Account" from the Hong Kong                             
            & Shanghai Banking Corp. dated December 1, 1990, bearing                                     
            petitioner's name and an account number (AssetVantage Account).                              
            Joint Exhibit 4-D consists of a copy of a transfer payment order                             
            dated December 18, 1990, from the Bank of America to the Hong                                
            Kong & Shanghai Banking Corp., showing a transferred amount of                               
            $23,000, listing David W. Chiu as remitter and David Woon Chiu as                            
            beneficiary, to the benefit of an account number identical to                                
            that shown on the AssetVantage Account.  Respondent objects to                               
            the admissibility of the handwritten marks on Exhibit 3-C on the                             
            grounds of relevance, authenticity, completeness, and hearsay.                               
            Respondent also objects to the admissibility of the entire                                   
            document comprising Exhibit 3-C on the ground of hearsay.                                    
            Respondent objects to the admissibility of Exhibit 4-D on the                                
            grounds of relevance and hearsay.  We hereby overrule                                        





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