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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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