Estate of Morton B. Harper, Deceased, Michael A. Harper, Executor - Page 20

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          over or income generated by the contributed property.  The estate           
          thus contends that this controversy devolves to a valuation case            
          where the property to be valued takes the form of partnership               
          interests in HFLP and where the analysis provided by the estate’s           
          expert Clint Cronkite establishes a sound appraisal thereof.                
          II.  Evidentiary Issues                                                     
               As a preliminary matter, we address several evidentiary                
          objections reserved by the parties in the stipulation of facts.             
          The estate objected to the admission of Exhibit 27-J on grounds             
          of authenticity, relevance, and prejudice.  Exhibit 27-J is a               
          facsimile of medical records for decedent requested by and sent             
          to the Internal Revenue Service.  The estate pointed out at trial           
          that the lines within the document for the doctor’s signature are           
          blank.  During the proceeding, respondent offered as Exhibit 53-R           
          signed copies of key portions of the records.  The estate agreed            
          that no objection would be pressed as to the authenticity of                
          Exhibit 53-R, at which time the document was admitted into                  
          evidence with the estate renewing objections as to relevance and            
          prejudice.  Given this posture, Exhibit 27-J is largely                     
          cumulative, and we sustain the estate’s objection thereto.  We              
          also overrule any remaining objections to Exhibit 53-R.                     
               The estate similarly objected to Exhibit 28-J on grounds of            
          authenticity, relevance, and prejudice.  This document is a                 
          letter to the Internal Revenue Service from one of decedent’s               

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