Doris F. Rabenhorst and Alvin P. Rabenhorst, Sr. - Page 9

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          554, 561-562 (1992).  Petitioners timely filed their original               
          gift tax returns in April 1989.  In late 1990, petitioners’ tax             
          counsel twice corresponded with a revenue agent regarding those             
          returns.  At some time subsequent to this correspondence,                   
          petitioners’ tax counsel advised petitioners that their 1988 gift           
          tax returns were being audited and that a deficiency was to be              
          proposed.  Accordingly, in early 1992, petitioners responded to             
          the actions of the Internal Revenue Service (IRS) by hiring                 
          Chaffe to evaluate, among other things, the 1988 stock transfer.            
          Upon receipt of Chaffe’s results, petitioners filed their amended           
          gift tax returns.                                                           
               We can find nothing unusual about this sequence of events.             
          Respondent apparently argues that, because petitioners hired                
          Chaffe to reevaluate the 1988 stock transfer after they were                
          advised of the examination and proposed deficiency, we should be            
          highly suspicious of the values petitioners now contend to be               
          proper.  In light of the facts before us, however, we think                 
          petitioners’ actions were typical under the circumstances.  Yet             
          this does not mean that we attribute any greater degree of                  
          confidence to petitioners’ recomputed values than we would have             
          otherwise attributed had petitioners filed their amended returns            
          prior to discovering that a deficiency was being proposed.                  
          Petitioners must carry their burden of proof; otherwise,                    
          respondent will prevail.  See id. at 577.                                   






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