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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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