- 6 - Mr. Garrett admits that collecting muscle cars was a personal hobby prior to the sale in 1989 and that he has no written documentation substantiating the claimed basis in the cars sold. Mr. Garrett also admits that prior to 1989, FGI and TTI issued checks to pay for the acquisition of the muscle cars. One or two years prior to trial, Mr. Garrett prepared from memory a reconstructed summary of expenses associated with the muscle cars sold in 1989. This reconstructed summary indicates purchase and renovation expenses totaling approximately $683,000 on the 25 cars sold in 1989. Mr. Garrett claims that this figure does not include any of the expenses improperly deducted by FGI, TTI, and BEL during 1989 and that a portion of the disallowed expenses should be added to this reconstructed figure to arrive at a total basis of $800,000. Petitioners did not produce any evidence that any corporate expenditures incurred during the years in issue were related to the specific cars sold in 1989. 2. Activities After 1989 Sale After the sale of the 25 muscle cars in 1989, Mr. Garrett began purchasing and refurbishing additional cars to add to his remaining collection of 10 cars. Other than the cars sold in 1989, Mr. Garrett did not sell any muscle cars during or after the years in issue.4 Petitioners did not claim any depreciation 4Mr. Garrett made occasional trades to get a better example of a particular car.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011