- 8 - $3,785,790. On August 15, 1985, the personal residence of petitioners was sold for $3,700,000 to satisfy creditor claims. This residence had been purchased by petitioners for $530,000. From the sale proceeds, the debt that was owed to Freedom Federal in the amount of $1,750,000 plus $550,000 in past due interest was paid in full. Ingersoll-Rand received $944,049 in partial satisfaction of its claims. The bankruptcy estate failed to file an estate tax return for 1985. After filing their personal petition in bankruptcy, petitioners moved to California. All of their personal assets, which became the property of the bankruptcy estate, were placed in storage. Among these items were important business documents and tax records. Petitioners were unable to retrieve these documents because the bankruptcy estate failed to make the proper storage payments. OPINION Petitioners bear the burden of proving that the determinations in the notice of deficiency are erroneous and that they are entitled to any deductions claimed on their returns. See Rule 142(a); INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992); Welch v. Helvering, 290 U.S. 111, 115 (1933). A recurring problem for petitioners at trial was a failure to provide adequate supporting documentation and receipts toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011