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Parties do not need to introduce complete versions of
documents. Under rule 106 of the Federal Rules of Evidence, the
adverse party “may require the introduction at that time of any
other part * * * which ought in fairness to be considered
contemporaneously with it.” Petitioners did not require the
introduction of the missing 279 Schedules K-1 or show that the
missing Schedules K-1 ought in fairness be considered with the
remainder of the partnership return.
Petitioners argue that the Schedule K-1 for Mr. Blonien
should not be admitted because respondent did not include “the
partner letter originally attached to the Schedule K-1”.
Respondent has confirmed that the Schedule K-1 filed with the
return did not include a partner letter. Petitioners have failed
to establish that the partner letter ought in fairness to be
considered with the Schedule K-1; petitioners’ authentication
objections are denied.
Petitioners also argue that these exhibits should not be
admitted because they are hearsay--offered to prove that Mr.
Blonien was a partner in Finley Kumble. Respondent responds that
these documents are not offered to show that Mr. Blonien was a
partner in Finley Kumble. The documents are offered to show that
Finley Kumble purported to be a partnership that would be subject
to the TEFRA proceedings and to show Finley Kumble’s state of
mind--that Finley Kumble treated Mr. Blonien as a partner. The
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