Daniel L. and Ingrid N. Carroll - Page 22




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          bear the burden of proof but on which they provided no expert or            
          other persuasive testimony.  In this regard they rely simply on             
          the Clearwater offering memorandum and ineffective cross-                   
          examination of respondent’s expert witnesses to establish the               
          value of the Sentinel EPE recyclers.                                        
              Similarly, petitioners failed to introduce persuasive                  
          evidence on pertinent factors to establish the economics of the             
          transaction, such as the presence of arm's-length price                     
          negotiations, see Helba v. Commissioner, 87 T.C. 983, 1005-1007             
          (1986), affd. 860 F.2d 1075 (3d Cir. 1988); the relationship                
          between the sales price and fair market value, see Zirker v.                
          Commissioner, 87 T.C. 970, 976 (1986); the structure of the                 
          financing, see Helba v. Commissioner, supra at 1007-1011; the               
          degree of adherence to contractual terms, see id. at 1011; and              
          the reasonableness of the income projections, see Rice's Toyota             
          World, Inc. v. Commissioner, 81 T.C. 184, 204-207 (1983), revd.             
          in part and remanded on other issues 752 F.2d 89 (1985).                    
               Petitioners contend that although they stipulated                      
          substantially the same facts concerning the underlying                      
          transactions that were described in Provizer v. Commissioner,               
          supra, they did not agree to be bound by any findings or                    
          conclusions in Provizer.  Although we do not hold petitioners to            
          the Provizer decision as a matter of stipulation, there is                  
          nothing in this record to persuade us to reach a different                  





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