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          with respect to the FPAA.  The computational adjustment changed             
          petitioner’s claimed DSBS 87-C loss of $16,720 to income of                 
          $4,421, increasing petitioner’s tax liability by $3,918, from               
          $724 to $4,642.  In the notice of deficiency underlying this                
          case, respondent determined that petitioner is liable for the               
          section 6662(a) accuracy-related penalty for negligence or                  
          disregard of rules or regulations with respect to the entire                
          amount of the underpayment resulting from the DSBS 87-C                     
          computational adjustment.                                                   
                                       OPINION                                        
          I.  Evidentiary Issues                                                      
               As a preliminary matter, we address evidentiary issues                 
          raised by the parties in the stipulations of facts.  The parties            
          reserved objections to a number of the exhibits and paragraphs              
          contained in the stipulations, all on the grounds of relevancy.             
          We address here those objections that were not withdrawn by the             
          parties at trial.  Federal Rule of Evidence 4021 provides the               
          general rule that all relevant evidence is admissible, while                
          evidence which is not relevant is not admissible.  Federal Rule             
          of Evidence 401 provides that “‘Relevant evidence’ means evidence           
          having any tendency to make the existence of any fact that is of            
          consequence to the determination of the action more probable or             
          1The Federal Rules of Evidence are applicable in this Court                 
          pursuant to sec. 7453 and Rule 143(a).                                      
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