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following sources: (1) Distributed income from the operation of
FGI and TTI; (2) more than $300,000 borrowed from FGI and TTI
from 1979 through 1988; (3) corporate bonuses of approximately
$100,000 per year; and (4) proceeds from the sale of several
parcels of real estate. In their attempt to support their
position that they actually paid for the muscle cars, petitioners
submitted their individual Federal income tax returns for taxable
years 1984 through 1988, as well as Forms 1120 and 1120S for FGI
and TTI for taxable years 1983 through 1988.
On the other hand, respondent argues that she disallowed the
claimed basis in the muscle car collection because petitioners
failed to present any evidence that established they actually
paid for the property. See sec. 1012. Respondent contends that
Mr. Garrett's corporations paid for the purchase and restoration
of the muscle cars; therefore, petitioners paid nothing from
their own funds for the collection sold in 1989.
We have reviewed petitioners' returns and do not find the
figures stated in these documents persuasive. Petitioners have
not provided this Court with any supporting documentation for
either their individual Federal income tax returns or the
corporate returns for the taxable years prior to 1989. Without
supporting documentation, such as bank statements, canceled
checks, and other corporate records, it is impossible to
determine conclusively the true origin of the funds used to
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