Bresnahan v. IRS
Case Date: 02/24/1998
Court: United States Court of Appeals
Docket No: 97-1708
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[NOT FOR PUBLICATION] UNITED STATES COURT OF APPEALS FOR THE FIRST CIRCUIT ____________________ No. 97-1708 JOHN BRESNAHAN, Petitioner, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent, Appellee. ____________________ ON APPEAL FROM THE DECISION OF THE UNITED STATES TAX COURT ____________________ Before Selya, Circuit Judge, _____________ Cyr, Senior Circuit Judge, ____________________ and Boudin, Circuit Judge. _____________ ____________________ John Bresnahan on brief pro se. ______________ Loretta C. Argrett, Assistant Attorney General, Teresa E. ____________________ ___________ McLaughlin and Thomas J. Sawyer, Attorneys, Tax Division, Department __________ _________________ of Justice, on brief for appellee. ____________________ FEBRUARY 20, 1998 ____________________ Per Curiam. We have carefully considered the record in ___________ this case, including the briefs of the parties and the decision of the court below. We affirm essentially for the reasons given by the tax court in its memorandum opinion, dated November 5, 1996. The two letters attached to petitioner's appellate brief, but not introduced into evidence before the tax court, are insufficient to sustain this appeal since we place no reliance on evidence not introduced below. See John Hancock ___ ____________ Mut. Life Ins. Co. v. United States, 155 F.2d 977, 978 n.1 ___________________ _____________ (1st Cir. 1946) (refusing to consider evidence on appeal which had not first been introduced in the court below). Affirmed. ________ -2- |