- 9 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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