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careful review of the record, we conclude that the discounted
per-share value of the 1988 stock transfer is $296.
Respondent’s argument is twofold. First, respondent
contends that the values attributed to the gifts of stock on
petitioners’ original gift tax returns constitute admissions on
their part and, as such, require “cogent proof” of incorrectness
before such values can be reduced. See, e.g., Estate of Hall v.
Commissioner, 92 T.C. 312, 337-338 (1989). Respondent also
contends that Willis was better situated to determine the
appraisal value of the stock transferred than was Chaffe.
Petitioners principally argue that they have carried their
burden in establishing that respondent’s determination is
incorrect. While we agree with respondent that the values
entered on petitioners’ original returns constitute admissions on
their part, we find petitioners’ argument persuasive with respect
to the fair market value of the 1988 stock transfer.
In Estate of Hall v. Commissioner, supra, we held that
amounts reported on a Federal estate tax return are admissions
and that lower values could not be substituted absent “cogent
proof” that the reported values were erroneous. We have also
applied this same principle to cases involving Federal gift tax
returns. See Mooneyham v. Commissioner, T.C. Memo. 1991-178. In
the present context, however, this cogent proof principle is
essentially synonymous with the general burden of proof set forth
in Rule 142(a). See generally Frazee v. Commissioner, 98 T.C.
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