8
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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