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authorities on documents are admissible under Fed. R. Evid.
803(15) as statements in documents affecting an interest in
property. deRochemont v. Commissioner, T.C. Memo. 1991-600.
Similarly, the report involves the assessment of taxes on the
property. Further, the report is required to be filed in order
for the State authorities to assess tax on the property
concerned. Cal. Rev. & Tax. Code sec. 480.3 (West 1998).
The statements within the report are relevant to the purpose
of the document--to assess the correct tax. In addition,
subsequent dealings with the property are not inconsistent with
the truth of the statement or purport of the document because
Angelo owns the entire property.
Accordingly, we admit this document into evidence under rule
803(15) of the Federal Rules of Evidence.
II. Stockton/Elsie Property
A. Abandonment Loss
Respondent argues that petitioner is not entitled to the
deduction for an abandonment loss because: (1) Petitioner
exchanged the property for Angelo’s guaranty that he would not be
responsible for any expenses that Angelo had already paid on the
property and future liabilities; (2) petitioner held the property
for the benefit of Angelo, and the property was, therefore, not
transferred to Angelo because Angelo already owned it; or (3)
petitioner did not abandon the property but transferred it to his
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