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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.
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Last modified: May 25, 2011