- 22 - 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 differentPage: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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