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Court were to sustain respondent's determinations with respect to
Radcliffe and BOT.38 Consequently, in the event we were to
sustain respondent's determinations with respect to Radcliffe and
BOT, respondent would have satisfied her burden under section
6902(a) of proving that petitioner is liable as a transferee of
each of those corporations.
The principal dispute in these cases is whether the deter-
minations with respect to Radcliffe and BOT should be sustained.
Petitioner bears the burden of demonstrating that those deter-
minations are erroneous. See sec. 6902(a); Rule 142(a); Welch v.
Helvering, 290 U.S. 111, 115 (1933); Zmuda v. Commissioner, 731
F.2d 1417, 1422 (9th Cir. 1984), affg. 79 T.C. 714 (1982).
Before turning to the various issues presented in these
cases, we note that we have given due consideration to all of the
parties' arguments and contentions with respect to those issues,
even though we do not attempt to address each of them herein.
I. Evidentiary Matters
Petitioner has attempted to satisfy his burden of proof
through testimonial and documentary evidence. Petitioner was the
principal witness on his behalf. We found him to be glib and at
38 Radcliffe and BOT each distributed property with a net value
of not less than $1,000,000 to petitioner as sole shareholder.
The net value of the property so distributed by Radcliffe and by
BOT exceeds the respective amounts of the deficiencies, additions
to tax, and penalties that respondent determined against peti-
tioner as a transferee of Radcliffe and of BOT.
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