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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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