Estate of Frank Johnson - Page 158




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          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 for               






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