Michael E. Yoakum - Page 8

                                        - 8 -                                         
          2002-25.  Petitioner has not met any of these requirements.                 
          While petitioner in retrospect apparently recognized that he had            
          not met this burden through the evidence that is contained in the           
          record, and attached to his brief an exhibit purporting to show             
          his NOL carryovers from 1986 through 1999, we give no                       
          consideration to that exhibit as it is not evidence.  See Rule              
          143(b); see also Harris v. Commissioner, T.C. Memo. 1998-332                
          (documents attached to a brief are not evidence).                           
               We sustain respondent’s determination as to this issue in              
          full.  All of petitioner’s arguments have been considered, and we           
          have concluded that those arguments not discussed herein are                
          without merit.  To reflect respondent’s concessions,                        

                                                  Decision will be entered            
                                             under Rule 155.                          






















Page:  Previous  1  2  3  4  5  6  7  8  

Last modified: May 25, 2011