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on account of finding the property, he would share in any profit
from developing the property. See supra sec. IV.D.3.b. There
was no development of the property, and respondent has failed to
show that Steven’s interest in the property was worth more than
the $10 that he received in consideration of the transfer. Also,
respondent has failed to carry his burden of proving that, at the
time of the transfer, Steven reasonably should have believed that
he would incur debts beyond his ability to pay them as they
became due. Respondent’s principal failure in that regard is the
same as his failure with respect to his showing of Steven’s
insolvency. See infra sec. IV.D.2. He has not shown Steven’s
assets, and, therefore, we cannot reach the conclusion that
Steven lacked the ability to pay. Nor can we infer that fact
from the fact that Steven did not pay his debts. Although the
parties have stipulated that, on September 28, 1995, Steven
incurred a criminal fine of $250,000, they have not stipulated,
nor is there any evidence, that Steven did not pay that fine when
it came due. Also, as stated, we have in evidence records of
assessments and payments pertaining to Steven’s taxable years
1988 through 1990. Respondent’s witness testified to some of the
entries on those records. She did not, however, testify that any
assessments shown on those records remain unpaid. The records
are not self-explanatory, and we will not presume to interpret
them ourselves, especially since respondent failed to propose any
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