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Petitioners resided in Cherry Hill, New Jersey, at the time
the petition was filed.
Petitioners are husband and wife, who made joint returns of
income for each of the years in question.
Petitioner husband (petitioner) is a successful businessman.
In 1983, petitioner opened a limousine leasing business under the
name "Scott's Limo & Leasing" (Scott's Limo). Scott's Limo was
conducted as a sole proprietorship. Exotic automobiles are
state-of-the-art, high technology vehicles with unique design
features or equipment. In 1987 and 1988, petitioner purchased
the following exotic automobiles (the exotic automobiles) to be
exhibited at car shows:
Year of Purchase Type Cost
1987 Lotus Pantera $63,000
1987 Lotus Espirit $48,000
1988 Gemballa FerrariTestarossa $290,453
During the years in issue, Scott's Limo displayed the exotic
automobiles at car shows and earned fees for doing so. For 1987
through 1990, Scott's Limo received gross income with respect to
the exotic automobiles as follows:
Year Gross Income
1987 $8,555
1988 38,120
1989 24,295
1990 25,760
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