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Finally, petitioners submitted a confused jumble of
corporate records that have not been properly organized,
reconciled, or explained. For example, PWIC’s records for 1989
extend only from January through May 21 and for the month of
October. The record reflects that petitioners were paid $25,000
by the insurance company for missing corporate documents in a
room leased to one of their corporations at the Crestwood
property.15 However, in this instance, we are confronted with a
multiplicity of missing documents from three different
corporations owned by petitioners.
Under these circumstances, petitioners’ testimony, without
further corroboration, is insufficient to carry petitioners’
burden. See Geiger v. Commissioner, 440 F.2d 688, 689 (9th Cir.
1971), affg. per curiam T.C. Memo. 1969-159; Mills v.
Commissioner, 399 F.2d 744, 749 (4th Cir. 1968), affg. T.C. Memo.
1967-67; Tokarski v. Commissioner, 87 T.C. 74, 77 (1986).
We hold that petitioners have failed to prove their
ownership of and/or depreciable basis in the vending machines and
that respondent’s determination regarding the depreciation is
sustained.16
15 The record is silent about which corporation leased the
room in the Crestwood property.
16 Our holding negates the need to reach respondent’s
argument that petitioners have not shown that the vending
machines have a useful life exceeding 1 year.
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