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First, petitioners argue that respondent did not subtract
outstanding checks from the balances of the bank accounts
transferred to JKY. We incorporate herein the above discussion
of that argument.
Second, petitioners argue that the actual transfer to JKY
consisted of $22,481.66 of business assets and $8,601.08 of
depreciation, not $33,546 of business assets and $17,114 of
depreciation as respondent determined. Petitioners offered an
undated document prepared by Caufield entitled "S Corporation 351
Transfer" as evidence that respondent's calculation of assets and
depreciation was incorrect. No supporting documents were
presented. Caufield testified at trial that this document
represented his initial computation of petitioners' section 351
transfer. He noted that at least one of the liabilities
represented on the document was in fact paid by the date of the
transfer and thus its inclusion was an error. Caufield also
testified that his calculation of the category "Fixed Assets",
unlike respondent's, did not include a 1982 Chevrolet van that
was sold by petitioners prior to the section 351 transfer. Yoon
did not testify about the transfer of assets to JKY. Other than
Caufield's testimony that the 1982 Chevrolet van was not included
in his calculation of fixed assets, we are provided with nothing
other than a summary with preliminary numbers and no support or
explanation. Petitioners have not presented sufficient evidence
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