James D. Barber and Betty L. Barber - Page 51

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          without merit.18                                                            
               To reflect our disposition of the disputed issues, as well             
          as petitioners’ concessions, see supra note 1,                              


                                                  Decisions will be entered           
                                             for respondent.                          



























               18  We also decline to consider arguments for which there is           
          no factual predicate in the evidentiary record.  See Rule                   
          143(b)(“statements in briefs * * * do not constitute evidence.”).           
          Further, insofar as additional interest under sec. 6621(c) may be           
          concerned, we refer petitioners to sec. 6621(c)(3)(A)(i), (v), as           
          well as Barlow v. Commissioner, T.C. Memo. 2000-339.                        

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