- 5 - and (B) to substantiate items, maintain records, and cooperate fully with respondent’s reasonable requests. Respondent claims that petitioners cooperated only partially and that petitioners produced only some of the documentary evidence they possess. At trial, petitioners admitted that they had not searched every location where relevant documents were likely stored. We agree with respondent that petitioners have not fully satisfied the requirements of section 7491(a)(2)(A) and (B), and, therefore, petitioners bear the burden of proof. II. Trust Distribution Petitioners received $170,000 or more in distributions from the trust following Mr. Purcell’s death. Petitioners acknowledge receipt of funds from the trust but assert that they were not provided sufficient information to determine whether the distributions constituted gross income. The distributions from the trust included but were not limited to the proceeds from Mr. Purcell’s life insurance policy, from the sale of his home, from the liquidation of his brokerage account, and from a liquidating distribution from his Roth IRA account. In an August 2003 letter to the Purcell sisters, Mr. Purcell’s estate planning attorney explained: “Other than IRA, 401k [sic], bond interest, and final pay, the amounts you inherit are income tax free.” The attorney informed the Purcell sisters that the section 401(k) plan maintained by Mr. Purcell’s employerPage: Previous 1 2 3 4 5 6 7 8 9 10 NextLast modified: March 27, 2008