Michael H. Johnson and Patricia E. Johnson - Page 10




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          (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             




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