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Respondent made a motion to strike the attachment from the record
as untimely.
Respondent’s motion to strike will be granted. The time for
presenting evidence is at trial. The parties may not introduce
new evidence after the trial has concluded and the record closed.
The Court does not try a case piecemeal. Moreover, statements in
briefs or in documents attached to briefs are not evidence and,
accordingly are not considered by the Court as such. Rule
143(b); Evans v. Commissioner, 48 T.C. 704, 709 (1967), affd. per
curiam 413 F.2d 1047 (9th Cir. 1969); Chapman v. Commissioner,
T.C. Memo. 1997-147; Berglund v. Commissioner, T.C. Memo. 1995-
536.
An order will be issued
granting respondent’s motion
to strike, and decision will
be entered for respondent.
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Last modified: May 25, 2011