- 27 - 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.Page: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
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