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his and his wife's many credit cards to make purported charges at
the auto shop. If so, the auto shop would then have been paid by
the credit card company for the charges, less of course the usual
discounts or fees charged by a credit card company to the
merchant (i.e., the auto shop); petitioners however would still
be liable to the credit card company for the full amount of the
purported charges. Assuming these "credit card loans" generated
funds (through float, delays in payments, failure to pay the
credit card company, etc.), there is nothing in the record to
show that the deposits to the auto shop bank account came from
any such "credit card loans". Without some tracing of funds
through the auto shop records, without some evidence that the
auto shop paid the expenses of the J car and did not deduct such
expenses either on petitioner's Schedule C's when the business
was operated as a sole proprietorship or on the corporation's tax
returns once the business was incorporated, there are simply too
many uncertainties for the Court to accept petitioner's self-
serving, generalized, and unsupported testimony.
The Court is satisfied that some expenses were incurred over
the years in designing and building the J car. The Court is not
satisfied that petitioner personally bore these expenses or has
any basis in the J car. The auto shop checkbook deposits cannot
with any reasonable certainty be tied to any costs that
petitioner incurred. As we have stated previously,
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