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Conclusion
We note that petitioner attached documents to his posttrial
briefs. Evidence must be submitted at trial; documents attached
to briefs and statements made therein do not constitute evidence
and will not be considered by the Court. Rule 143(b); Evans v.
Commissioner, 48 T.C. 704, 709 (1967), affd. per curiam 413 F.2d
1047 (9th Cir. 1969); Lombard v. Commissioner, T.C. Memo.
1994-154, affd. without published opinion 57 F.3d 1066 (4th Cir.
1995). Accordingly, these documents are not in evidence.
To reflect the foregoing,
Decision will be entered
for respondent.
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