Lawrence Robert Clifton-Bligh - Page 6

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          689-690 (9th Cir. 1971), affg. per curiam T.C. Memo. 1969-159;              
          Tokarski v. Commissioner, 87 T.C. 74, 77 (1986).                            
               We hold that petitioner is not entitled to claim loss                  
          deductions in any amount for any of the years in issue relating             
          to SJC, Lloyd’s, Marisco, C Films, and SSS.                                 
          Remaining Issues                                                            
               Petitioner did not present any evidence at trial regarding             
          any of the remaining issues he raised in his petition.                      
          Therefore, we conclude that petitioner has abandoned these                  
          issues.  Petzoldt v. Commissioner, 92 T.C. 661, 683 (1989); Money           
          v. Commissioner, 89 T.C. 46, 48 (1987).                                     
               At the conclusion of the trial, the Court advised petitioner           
          that once the trial was finished the record would be closed and             
          petitioner would not be able to submit additional evidence.                 
          Petitioner attached to his posttrial briefs documents he argues             
          support the deductions and losses he claims he is entitled to for           
          the years in issue.  Evidence must be submitted at trial;                   
          documents attached to briefs and statements therein are not                 
          evidence.  Rule 143(b); Lombard v. Commissioner, T.C. Memo. 1994-           
          154 n.3, affd. without published opinion 57 F.3d 1066 (4th Cir.             
          1995); Wicker v. Commissioner, T.C. Memo. 1993-431 n.15, affd.              
          without published opinion 50 F.3d 12 (8th Cir. 1995).                       
          Accordingly, we disregard these documents in reaching our                   

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