- 6 - 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 decision.Page: Previous 1 2 3 4 5 6 7 Next
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