Charles R. Bowden and Sue I. Bowden - Page 27

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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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