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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 ordinary
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