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was created when petitioner transferred any assets, including the
Whittington property to AIM. We find that the promissory note
does not establish that there was a genuine debt. In re Lane,
supra; Stinnett’s Pontiac Serv., Inc. v. Commissioner, supra;
Tyler v. Tomlinson, supra.
The balance sheets submitted by AIM to the Mississippi and
Alabama licensing boards in 1992 and to Citizens National Bank
show that shareholders had lent only $30,000 to AIM. Similarly,
a balance sheet that AIM submitted to the Alabama licensing board
in December 1993 shows that shareholders had lent only $37,406 to
AIM. The only documents that state that AIM owed $121,596 to
petitioner are the promissory note and AIM’s 1992 tax return.
AIM’s 1992 return does not establish that AIM owed petitioner
that amount because tax returns do not establish the truth of the
facts stated in them. Lawinger v. Commissioner, 103 T.C. 428,
438 (1994); Wilkinson v. Commissioner, 71 T.C. 633, 639 (1979);
Roberts v. Commissioner, 62 T.C. 834, 837 (1974). In deciding
whether petitioner and AIM created a bona fide debt, we give more
weight to the balance sheets than to the promissory note because
the balance sheets were AIM’s official representations of its
assets and liabilities to Government agencies and to its bank.
Petitioners contend that we should ignore the balance sheets
and statements that conflict with the note because petitioner was
not knowledgeable about financial documents when they were
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