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the listed liabilities are personal liabilities of petitioners or
corporate liabilities (i.e., liabilities of Mr. Johnson's car
dealership); (3) if the liabilities are personal liabilities, it
is unclear whether they are joint liabilities or separate
liabilities of either Mr. Johnson or Mrs. Johnson; (4)
petitioners failed to identify which assets are community
property and which are separate property; and (5) the $2 million
net worth limitation applies separately to each taxpayer, and the
first joint net worth schedule lists the aggregate net worth of
petitioners as less than $4 million but does not establish the
net worth of each petitioner.
Petitioners filed a reply to respondent's objection and
again submitted an affidavit that stated their net worth was less
than $4 million jointly and $2 million individually. Petitioners
also submitted three net worth schedules: One listing the net
worth of both petitioners as of the date the petition was filed
(second joint net worth schedule), one listing the net worth of
Mr. Johnson as of the date the petition was filed (Mr. Johnson's
net worth schedule), and one listing the net worth of Mrs.
Johnson as of the date the petition was filed (Mrs. Johnson's net
worth schedule).
The second joint net worth schedule listed the following
assets:
5(...continued)
96 (1996).
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