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investment." The four checks in question match the obligations
purportedly imposed on Sheldon. We have no reason to believe
that any additional payments were required to be made or were
made. Respondent does not suggest that (1) any other witnesses
or books and records might show any other payments, or (2) that
Nancy had a source for making any other payments. We reject
respondent's attempts to create uncertainty by making unfounded
speculations, and then to capitalize on that uncertainty by
invoking Wichita Terminal Elevator Co. v. Commissioner, 6 T.C.
1158, 1165 (1946), affd. 162 F.2d 513 (10th Cir. 1947).
Petitioners have convinced us, and we have found, that
Sheldon made all the payments that were made. We do not see the
loose ends that respondent speculates about. We believe that the
instant case does not provide a proper basis for invocation of
the Wichita Terminal doctrine.
We hold for petitioners on this issue.
B. Knowledge or Reason to Know
Respondent contends that Nancy's testimony "should not be
relied upon" and that "it is likely that Mr. Silverman informed
her of the investment in State Coal". Respondent also contends
that, even if Nancy did not in fact know of the State Coal
investment, she should have known, because Nancy should be held
to at least as high a standard of review of the tax return as
would a taxpayer who had actually signed the tax return, and if
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