Jay M. Anderson and Helen B. Anderson - Page 18

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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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