- 5 - 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 netPage: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011