Floyd L. Garrett and Dorothy G. Garrett - Page 10

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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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