World of Service, Inc. - Page 17

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             23.  Great has not shown that it did not realize income from             
           forgiveness of indebtedness due to the cancellation of                     
           promissory notes due to Tipuani.                                           
             24.  Great has not shown that it is entitled to the $812 of              
           aircraft and pilot fees disallowed by respondent for the FYE               
           July 31, 1983.                                                             
             25.  Petitioners failed to keep adequate records of their                
           deduction items.                                                           
                                        OPINION                                       
             Regarding those items on which the parties could not settle,             
           the trial of this case covered 5 taxable years of the two                  
           corporate petitioners.  Numerous deduction items were in                   
           controversy, and we have reviewed the record with respect to               
           each of them and made specific and ultimate findings for each.             
           In this portion of the opinion, we express the standards under             
           which petitioners' controverted items were judged, and we                  
           analyze and make additional ultimate findings regarding the                
           additions to tax with respect to both petitioners.                         
             Petitioners bear the burden of proving that they are entitled            
           to the deductions claimed, or of showing that respondent erred             
           in the determination.  Rule 142(a); New Colonial Ice Co. v.                
           Helvering, 292 U.S. 435, 440 (1934).  In addition, petitioners             
           are required to maintain adequate records to substantiate their            
           claimed deductions.  Sec. 6001.  Petitioners were closely held             
           corporations owned and operated by the Johnsons.  The                      




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