- 9 - 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, 341Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011