Joseph D. Park and Mi Jung Park, et al. - Page 5




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          meet the net worth requirements”, and that “the taxpayer must               
          provide supporting information (i.e., evidence) to establish his            
          net worth”).  Like the taxpayers in Dixson, petitioners “failed             
          to provide any supporting information to establish their net                
          worth or to even address the issue in their supplemental motion”.           
          Dixson Intl. Serv. Corp. v. Commissioner, supra at 719.                     
               Petitioners received over $9 million from Messrs. Latief and           
          Tandiono and transferred significant amounts of money amongst               
          themselves.  In addition, David has maintained his close                    
          relationship with Mr. Tandiono.  Indeed, he resided in Mr.                  
          Tandiono’s $2.4 million home at the time the petition was filed,            
          and we have no knowledge of assets acquired up to that time.                
          Respondent contends that the affidavits petitioners submitted are           
          insufficient and that petitioners failed to produce additional              
          evidence (e.g., net worth statements or financial statements)               
          demonstrating that their net worth is less than $2 million.  We             
          agree.                                                                      
               It is reasonable, under the unusual facts of this case, to             
          believe that petitioners may have considerable net worth.                   
          Petitioners, however, submitted no evidence to support their                
          affidavits and failed to address the issue in their supplement.             
          See id.; Johnson v. Commissioner, supra; cf. Prager v.                      
          Commissioner, T.C. Memo. 1994-420 (holding that the taxpayer, who           
          initially produced a one-sentence affidavit, satisfied the net              






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