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December 2, 1999 transaction. We have found on the record pre-
sented that petitioners have failed to carry their burden of
showing, let alone by strong proof, that the December 2, 1999
transaction was some type of venture with respect to lot 5 be-
tween Mr. O’Malley and Kevin O’Malley pursuant to which petition-
ers claim, inter alia, that Kevin O’Malley lent petitioners
$54,400 of the $254,400 F&M Bank 1999 loan. We have further
found on that record that, at all relevant times after the Decem-
ber 2, 1999 transaction, (1) Kevin O’Malley (a) continued to live
in the house located on lot 5, (b) ceased paying rent to peti-
tioners with respect to that lot, and (c) made payments to F&M
Bank with respect to the $254,400 F&M Bank 1999 loan; and
(2) petitioners did not make any payments to F&M Bank with re-
spect to that loan. We have also found on the record presented
that petitioners have failed to carry their burden of showing,
let alone by strong proof, that, after the December 2, 1999
transaction, petitioners, and not Kevin O’Malley, (1) were vested
with the right of possession with respect to lot 5 or (2) paid
the expenses (e.g., real property taxes) with respect to that
lot. Finally, we have found on the record presented that peti-
tioners have failed to carry their burden of showing, let alone
by strong proof, that, after the December 2, 1999 transaction,
they retained the benefits and burdens of ownership with respect
to lot 5. The record simply does not support petitioners’ asser-
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