Zeeman Manufacturing Company, Inc. - Page 23

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          to earn a 4-A credit rating.  The burden of proof therefore                 
          remains with petitioner as to the sixth ground.                             


               7.   Technology                                                        
               Petitioner states that, during each of its 1992 and 1993               
          taxable years, it reasonably accumulated $300,000 to purchase a             
          new computer system.  Petitioner states that, during 1992, it               
          adopted a plan to purchase a new system, which is conservatively            
          estimated to cost $300,000.                                                 
               Respondent contends that petitioner has not provided the               
          names of companies that it met with to purchase a new system or             
          any bids that it may have received.  Additionally, respondent               
          argues that petitioner does not state the type of computer system           
          that it needs or the terms of the plan it adopted during 1992.              
               We hold that petitioner has not disclosed in its statement             
          sufficient details to permit respondent to prepare for trial.               
          Petitioner provided the cost of the computer system that was                
          implemented during 1991 through 1993 (which became obsolete) but            
          did not indicate any specific plans for the purchase of a new               
          computer system.  Moreover, petitioner did not provide any                  
          details showing that petitioner's management decided during its             
          1992 and 1993 taxable years to accumulate $300,000 for that                 
          purpose.  Accordingly, we hold that the burden of proof remains             
          with petitioner as to the seventh ground.                                   






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