Zeeman Manufacturing Company, Inc. - Page 7

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          respondent is not required to guess as to what they may be."                
          Hughes, Inc. v. Commissioner, 90 T.C. at 18-19.                             
               If petitioner's statement with respect to a particular                 
          ground provides sufficient facts to support an assertion that               
          some accumulation was reasonable but fails to provide sufficient            
          facts to support the full amount of the accumulation, then we               
          will impose the burden of proof on respondent only to the extent            
          the supporting facts are sufficiently disclosed.  Petitioner                
          bears the burden of proof for amounts in excess of those                    
          supported in the statement.  Rule 142(a); Soros Associates Intl.,           
          Inc. v. Commissioner, supra.  Additionally, petitioner bears the            
          burden of proof with respect to any grounds or amounts not                  
          mentioned in the statement.  Sec. 1.534-2(a)(2), Income Tax Regs.           
               For purposes of the accumulated earnings tax, the term                 
          "reasonable needs of the business" includes the "reasonably                 
          anticipated needs of the business".  Sec. 537; Technalysis Corp.            
          v. Commissioner, 101 T.C. 397, 409 (1993).  If the facts                    
          disclosed in the statement are sufficiently substantial,                    
          material, definite, and clear to permit respondent to prepare for           
          trial, the statement will be deemed sufficient as to such                   
          grounds.  J.H. Rutter Rex Manufacturing Co. v. Commissioner, 853            
          F.2d 1275, 1283 (5th Cir. 1988), affg. in part, revg. in part and           
          remanding T.C. Memo. 1987-296; see also Thompson Engg. Co. v.               
          Commissioner, 80 T.C. 672, 693 (1983), revd. on another issue 751           
          F.2d 191 (6th Cir. 1985).                                                   




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