- 24 -
Memo. 1986-325. Petitioner sought to raise this issue late in
the trial. We ruled that the issue was not timely, and therefore
we would not consider it. We affirm that ruling now. See Aero
Rental v. Commissioner, 64 T.C. 331, 338 (1975); Palmer v.
Commissioner, 62 T.C. 684, 698 (1974), affd. 523 F.2d 1308 (8th
Cir. 1975).
To reflect concessions and the foregoing,
Decision will be entered
under Rule 155.
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