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the first joint net worth schedule to the second joint net worth
schedule.
Additionally, petitioners included an annuity as an asset in
the first joint net worth schedule but did not list this asset in
the second joint net worth schedule or in their individual net
worth schedules. The second joint net worth schedule also
included over $600,000 in taxes that was not listed on the first
joint net worth schedule. Petitioners did not explain any of
these discrepancies.
Petitioners supplied no explanation why their calculations
of their net worth as of the time the petition in the case was
filed changed so drastically in the less than 2 months between
the submission of their original motion (which contained the
first joint net worth schedule) and their reply to respondent's
objection (which contained the second joint net worth schedule
and the individual net worth schedules).
Under the circumstances present in this case, we do not feel
compelled to accept petitioners' unsubstantiated, conclusory, and
self-serving assertion that they meet the net worth
requirements.6 See Estate of Hubberd v. Commissioner, supra;
Dixson Intl. Serv. Corp. v. Commissioner, supra; see also McCoy
6 On Apr. 12, 1999, petitioners filed a "Statement of
Errata" in which they state that their joint net worth schedules
contained several errors due to "misunderstandings" and
"miscommunications". Petitioners attached a third joint net
worth schedule that listed their combined net worth as
$1,097,312. Petitioners submitted no evidence supporting the
amounts listed in this schedule. We believe that this submission
further supports our conclusions in this case.
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