Herschel H. and Roberta S. Hoopengarner - Page 13

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          when the properties were foreclosed upon.  For example, in 1989,            
          petitioners reported adjusted gross income of zero.  In 1990,               
          petitioners reported adjusted gross income of -$820,198.                    
          Petitioners contend that losses from foreclosures on the five               
          properties created the net operating losses.  Based on the                  
          stipulated facts in this case, however, four of the properties              
          were foreclosed upon between 1982 and 1985, and the fifth                   
          property was not foreclosed upon until 1992.  This is one of the            
          many inconsistencies evident in petitioners’ case.                          
               Petitioners have failed to offer credible testimony to meet            
          their burden of substantiation in this case.                                
               3.   Petitioners Provided No Financial Records                         
               Petitioners failed to provide any financial documentation to           
          substantiate the net operating losses.  Petitioners did not                 
          produce books or records for the alleged loss years to                      
          substantiate the claimed losses.  Petitioners provided no                   
          financial statements from the H & H partnership.  Petitioner                
          conceded that he does not have any records for the properties or            
          the H & H partnership, as his partner Mr. Hornbeak retained all             
          the records.  Petitioner failed to obtain these records from Mr.            
          Hornbeak.  Petitioners provided no financial statements from H &            
          H Land Development Corp.  Petitioners provided no receipts as to            
          losses on the property.  Petitioners provided no information as             








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