Michael H. Johnson and Patricia E. Johnson - Page 6




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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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