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Liabilities Value
Unsecured bank loans $35,514
Secured loans 235,500
Taxes payable 309,610
Real estate loans:
First Union Mortgage 200,891
CA-Jon Hangar project loan 295,570
CRV 856,047
Havasu rental 80,194
Antelope Valley Ford & Shuttle
Lincoln-Mercury facilities loan 1,854,980
Total liabilities 3,868,305
Mr. Johnson's net worth schedule and Mrs. Johnson's net worth
schedule determined the individual net worth of each petitioner
to be ($1,945,988).
Essentially, petitioners split the amounts contained on the
second joint net worth schedule in half, attributing one-half to
Mr. Johnson and the other half to Mrs. Johnson.
Petitioners argue that to satisfy the net worth requirements
they only need to submit a statement, supported by an affidavit
executed by the moving party, that they meet the net worth
requirements. We disagree.
Petitioners were put on notice that respondent was
specifically objecting to an award of administrative and
litigation costs because petitioners failed to prove they meet
the net worth requirements. After a taxpayer is put on notice
that the Commissioner is specifically objecting to an award of
administrative and/or litigation costs because of the taxpayer's
failure to prove his net worth, the taxpayer must provide
supporting information (i.e., evidence) to establish his net
worth. See Estate of Hubberd v. Commissioner, 99 T.C. 335, 341
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Last modified: May 25, 2011