- 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