Allen C. Chamberlin and Martha L. Chamberlin - Page 8

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          $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.                                                           
               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 to                   

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