- 86 - tax payments made during 1988. Respondent does not explain why $1,500 is used instead of $3,000. Petitioners do not explain why they disagree with this item. Statements in tax returns constitute admissions unless overcome by cogent evidence that they are wrong. See, e.g., Waring v. Commissioner, 412 F.2d 800, 801 (3d Cir. 1969), affg. per curiam T.C. Memo. 1968-126. On the basis of the foregoing, we conclude that respondent’s use of $1,500 for estimated tax payments is reasonable; accordingly, we hold that no adjustment for that item is required in Ronnie’s source and application of funds analysis for 1988. d. Tax Payment In the source and application of funds analysis for Ronnie for 1988, see infra Appendix G, respondent included as an application of funds $5,319 for 1987 tax payments. Ronnie’s tax return for 1987 shows zero tax payments made during 1987 and a tax due of $5,216. Respondent does not explain why $5,319 is used instead of $5,216. Petitioners do not explain why they disagree with this item. On the basis of the foregoing, we conclude that a charge for 1987 tax payments is reasonable; we hold, however, that the amount for that item should be $5,216. e. Wedding Ceremony for Sylvia In the source and application of funds analysis for Frank and Katherine for 1989, see infra Appendix A, respondent included as an application of funds $10,000 for a wedding ceremony forPage: Previous 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 Next
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