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Schedules C for the auto shop or on the later corporate returns
of the auto shop.
In 1985, petitioner sold the auto shop. At that time he
drove the J car, without windows or a muffler, the 5 miles to his
home. This is the only mileage that has ever been put on the J
car. By the time the J car was moved to petitioner's home, some
99 percent of the costs of the car had been incurred. Thereafter
petitioner merely invested his time and labor in completing the
vehicle.
On August 19, 1986, petitioner filed a petition in the
Bankruptcy Court for the Western District of Virginia seeking
relief under Chapter 13 of the Bankruptcy Code. Petitioner's
debts included unpaid withholding tax for the auto shop, bank
loans for real estate purchases, and some unsecured debts
possibly including unpaid credit card charges. In his bankruptcy
petition, petitioner listed among his personal property the J
car, describing it as a 1965 Spitfire worth $1,000. It was
listed according to its frame. The J car was never titled with
the State motor vehicle authority and has never been insured. In
August of 1986, the J car had been disassembled, and its parts
were lying all over petitioner's garage. Petitioner claims that
he valued the car at $1,000 because of its then disassembled
condition.
From 1986 until 1989, petitioner worked on finishing the J
car at home. He reassembled the J car and put on the lacquer
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