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1. Outstanding Liabilities
Petitioners contend that respondent failed to reduce
petitioners' net worth by outstanding liabilities, mainly credit
card debts and debts to friends and relatives.
a. Credit cards. Respondent did not include in her net
worth determination petitioners' personal credit card
liabilities.
Petitioners failed to provide any reliable evidence from
which we can establish or even estimate their credit card
liabilities as of December 31, 1988, or January 1, 1989. At
trial, petitioners presented, as part of their personal living
expense calculations, schedules prepared by Caufield that state
alleged opening dates of certain credit card accounts. No
supporting documents were attached to these schedules, and Yoon
did not testify regarding the establishment of any of the credit
card accounts. Without a reliable opening balance as of
January 1, 1989, we cannot determine whether this debt increased
or decreased during the year. Thus, we cannot adjust
respondent's net worth determination for 1989 by any credit card
liabilities.
At trial, petitioners produced a schedule of credit card
balances at the end of 1989, 1990, and 1991 with copies of
certain monthly credit card statements attached. These schedules
and copies of statements are reliable evidence of petitioners'
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