- 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.
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