- 49 - These numbers were described in the explanation of items as “counts any hotels actually managed by” the respective entity; i.e., HHK, HS, or HP. OPINION I. Preliminary Matters--Evidentiary Objections A. Documents Executed During or Pertaining to Taxable Years Subsequent to Those in Issue Respondent objected, on the grounds of relevance, to the admission into evidence of certain documents executed during and/or pertaining to periods subsequent to the taxable years in issue. Alternatively, respondent objected on the grounds that any probative value of such documents is outweighed by prejudice or considerations of undue delay, waste of time, or the needless presentation of cumulative evidence. The documents in question primarily include management agreements and financial statements of Hyatt International hotels. Respondent’s objections, in essence, bear more heavily on the probative weight of the documents than on their admissibility. It is noted that respondent did not object to documents concerning subsequent periods when the documents supported or were helpful to respondent’s expert’s opinion. Respondent relies on rules 401, 402, and 403 of the Federal Rules of Evidence. Under the circumstances here, we hold that the documents to which respondent objected are relevant andPage: Previous 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 Next
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