USCA1 Opinion
[NOT FOR PUBLICATION]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. ________
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