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for Mrs. Bowden’s travel to Japan where she had relatives and
allegedly explored business opportunities. We do not accept
petitioners’ uncorroborated testimony on these items.
We also find it telling that petitioners were able to submit
complete corporate records for certain time periods but that
records were incomplete for other time periods. Even factoring
in a loss of records due to the Crestwood property floods, there
remain unexplained inconsistencies concerning the corporate
records. For example, petitioners did not present a coherent
explanation why particular corporate records were located at the
Crestwood property and not at other business locations. Also,
petitioners were able to submit to respondent the complete
general ledgers for PWIC’s 1986 calendar year. We do not
understand why these particular ledgers were unaffected by the
Crestwood property floods while PWIC’s records for 1989 are
incomplete.
Also, petitioners do not address the fact that C.B. Crest’s
records do not include the months of September, November, and
December 1989 as well as the complete month of August 1989.
Petitioners cannot attribute the absence of these records to the
December 1987 and June 1988 Crestwood property floods.
Accordingly, we sustain respondent’s determination that
petitioners are liable for tax on the expenditures paid by the
corporations. Petitioners have failed to show that these
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