Arun and Asmita Bhatia - Page 8

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          stipulation that petitioner, were he to testify in this case,               
          would state that, in 1988, he reduced his basis in GCC by                   
          $244,500.  Petitioners assert that this reduction prevented them            
          from taking advantage of deductions in that amount in respect of            
          losses of AB 89 Street Corp., an S corporation into which GCC was           
          merged in 1990, and which, as reflected in the stipulated tax               
          returns, had net operating losses for 1989 through 1992.                    
               Our evaluation of this argument takes into account the rule            
          that submitting a case fully stipulated does not lessen the need            
          for petitioners to carry their burden of proof.  Borchers v.                
          Commissioner, 95 T.C. 82 (1990), affd. 943 F.2d 22 (8th Cir.                
          1991).  In this connection, we note that, aside from the                    
          stipulated assumption agreement, the stipulated tax returns, and            
          the stipulated testimony of petitioner, there is no evidence in             
          respect of the actual existence of an indebtedness of ABDC to GCC           
          or of the amounts or terms of that indebtedness as to interest or           
          time of repayment or of petitioner's basis in GCC before or after           
          the claimed reduction.                                                      
               The evidence in support of petitioners' position is skimpy             
          at best.  Tax returns are not proof of the statements contained             
          therein.  Lawinger v. Commissioner, 103 T.C. 428, 438 (1994). Nor           
          do we consider the stipulated conclusory statement by the                   
          taxpayer sufficient to carry the day in respect of the                      
          bookkeeping entries of GCC.  Shebester v. Commissioner, T.C.                
          Memo. 1987-246.  In Shebester, the taxpayer was a majority                  




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