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Commissioner, 82 T.C. 413, 431-432 (1984), affd. without
published opinion 772 F.2d 910 (9th Cir. 1985).
Generally, the Commissioner’s determinations are presumed
correct, and the taxpayer bears the burden of proving by a
preponderance of evidence that those determinations are
erroneous. See Rule 142(a); Welch v. Helvering, 290 U.S. 111,
115 (1933).
Petitioner has not alleged any error in respondent’s
determination of his opening net worth, except as relates to
$10,000 that respondent treated petitioner as having paid as a
downpayment for the Carskadon farm in 1987. Petitioner argues
that he borrowed the $10,000 from a friend, thus suggesting that
this sum should not be included in his net worth computation (or
else the computation should reflect a corresponding decrease for
his outstanding liability). The evidence in the record–-
consisting of two conflicting statements from the now-deceased
friend–-is inconclusive as to whether petitioner made the down-
payment with borrowed funds. Any error by respondent in this
regard, however, was harmless. Since the farm was bought in 1987
and the treatment of the downpayment remained unchanged
throughout the years in issue, the final result of the net worth
computation was unaffected by this item. Cf. United States v.
Scrima, 819 F.2d 996, 999 (11th Cir. 1987). We conclude and hold
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