- 239 - used for personal purposes, and they made only general comments that the cars were used mostly for business. Additionally, in 1976 petitioner formed CDC. His son-in- law, Mr. Dinunzio, was employed by CDC and its various subsidiaries. Mr. Dinunzio also worked on McZand Corporation projects. He used the automobile provided by petitioner in his employment for McZand Corporation and CDC and its subsidiaries. Mr. Dutton was also provided with a car by petitioner, as were Clem and Priscilla Meier. Each of these individuals used the cars provided by petitioner in their employment with CDC, subsidiaries of CDC, or partnerships in which CDC was a partner. We conclude that petitioner failed to present sufficient evidence to prove that he is entitled to depreciation on the automobiles he purchased for his use and the use of others. No records were maintained to show the business use of the automobiles. There is also little evidence of petitioner's business activities in and around the Columbus, Ohio, area. His clients and customers were spread throughout the United States. He claimed and was allowed significant amounts for travel expenses in meeting with those clients. In addition, for the years 1977 through 1980 the use of the automobiles by Mr. Dinunzio, Mr. Dutton, and the Meiers was related to the activities of McZand Corporation or CDC. Thus, any automobile use on behalf of those entities would not constitute an ordinaryPage: Previous 229 230 231 232 233 234 235 236 237 238 239 240 241 242 243 244 245 246 247 248 Next
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