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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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