J.J. Zand - Page 163

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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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