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2. Accounts Payable
Petitioners contend that if their net worth is increased by
accounts receivable, it should also be reduced by accounts
payable. Petitioners contend that total liabilities as of year-
end 1995 should be increased by a number of accounts payable that
were outstanding on December 31, 1995. Petitioners offered
documentary evidence of construction costs incurred in 1995 but
not paid until 1996. On brief, respondent does not dispute that
his net worth analysis omits these amounts from accounts payable
but attacks the probative value of petitioners’ evidence. On the
basis of our detailed review of the evidence, we conclude and
hold that $30,786.54 of such accounts payable should be included
in petitioners’ net liabilities as of year-end 1995 for purposes
of the net worth analysis.
3. Value of Netherland Inn Road Property
In his net worth analysis, respondent included in
petitioners’ 1993 opening net worth $109,000 as the value of
petitioners’ property on Netherland Inn Road. Petitioners
contend that the value should be increased to $127,000, based on
Jack’s testimony that petitioner added an improvement to the
property “at a cost of approximately $18,000.” The only other
evidence on this point consists of the hearsay testimony of
petitioner’s out-of-State accountant. On the Schedule D, Capital
Gains and Losses, attached to their 1993 return, petitioners
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