- 10 -
(1992); Dixson Intl. Serv. Corp. v. Commissioner, 94 T.C. at 719;
see also McCoy v. Commissioner, T.C. Memo. 1992-423.
Petitioners submitted no evidence supporting the amounts
listed in the various net worth schedules or the statements in
their original motion and supporting affidavits that they meet
the net worth requirements. Furthermore, respondent submitted
evidence that the land upon which Mr. Johnson's motor vehicle
dealerships are located is Mr. Johnson's sole and separate
property. Petitioners, in their reply, failed to address whether
this or any other property listed on the various net worth
schedules was separate or community property. Additionally,
petitioners included half the value of each property in both Mr.
Johnson's net worth schedule and Mrs. Johnson's net worth
schedule.
The various net worth schedules submitted by petitioners
leave doubt as to their veracity. The first joint net worth
schedule and the second joint net worth schedule are almost $8
million apart as to petitioners' joint net worth as of the date
the petition was filed. The amounts listed on the second joint
net worth schedule changed by tens of thousands of dollars for
petitioners' checking and savings accounts, changed by hundreds
of thousands of dollars for their investment in the dealership,
and changed by millions of dollars for their real estate from the
amounts listed on the first joint net worth schedule.
Petitioners' liabilities also increased by over $3 million from
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011