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As further support for respondent’s position that York did
not acquire the loans to shareholder accounts, we note that
“Loans to stockholder” of $111,484 are listed as an asset at
yearend on both the Schedules L filed with Mid-Nebraska’s tax
returns for 1992 and 1993. Statements on a Federal tax return
are admissions under rule 801(d)(2) of the Federal Rules of
Evidence and will not be overcome without cogent evidence that
they are wrong. See, e.g., Waring v. Commissioner, 412 F.2d 800,
801 (3d Cir. 1969) (“The valuation [of license agreement] given
in the return was an admission, and although it is not
conclusive, the Tax Court was entitled to judge its weight as
evidence.”), affg. per curiam T.C. Memo. 1968-126; United States
v. Hornstein, 176 F.2d 217, 220 (7th Cir. 1949) (cost of goods as
shown on return were chargeable to taxpayer until he offered
credible evidence that figures were in error); Estate of Hall v.
Commissioner, 92 T.C. 312, 337-338 (1989) (values of stock
reported on estate tax return are admission by taxpayer, and
lower value could not be substituted without cogent proof that
reported values were erroneous); Lare v. Commissioner, 62 T.C.
739, 750 (1974) (“Statements made in a tax return signed by a
taxpayer may be treated as admissions.”), affd. without published
opinion 521 F.2d 1399 (3d Cir. 1975). Petitioners have failed to
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