Stephen J. Roling and Peggy A. Roling - Page 12




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               As to that argument, respondent asserts that it was                    
          incumbent upon petitioners to substantiate the fact and amount of           
          the loan.  It is reasonable, according to respondent, not to                
          concede an adjustment until he has received and verified adequate           
          substantiation for the item in question.  He therefore concludes            
          that as to the unreported income adjustment, his position was               
          reasonable when taken and appropriately conceded when                       
          substantiation was provided to Appeals.                                     
               Petitioners argue that they provided to Appeals a copy of a            
          "loan document" that verifies a $10,000 loan received by them               
          from petitioner's father.  Mere presentation of a note or "loan             
          document" may not be sufficient evidence of the existence of such           
          a loan.  See Sullivan v. Commissioner, T.C. Memo. 1985-217.                 
          Further documentation and testimony might be required.  See Kim             
          v. Commissioner, T.C. Memo. 2000-83; Coutsoubelis v.                        
          Commissioner, T.C. Memo. 1993-457; Facuseh v. Commissioner, T.C.            
          Memo. 1988-10; Mahigel v. Commissioner, T.C. Memo. 1983-529;                
          Adams v. Commissioner, T.C. Memo. 1980-398.                                 
               It is reasonable for respondent to make an adjustment for an           
          item and refuse to concede the adjustment until he has received             
          and verified petitioners' substantiation for the amount adjusted.           
          See Beecroft v. Commissioner, T.C. Memo. 1997-23; Simpson                   
          Financial Servs., Inc. v. Commissioner, T.C. Memo. 1996-317;                
          McDaniel v. Commissioner, T.C. Memo. 1993-148.                              






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