- 13 - And the last item was Mr. Garrett had bought and sold some real estate. He was also a shrewd investor in real estate, and I presumed that some of those profits from real estate transactions had probably gone into this. So I satisfied myself that he could have put up to that 800,000, and I was--and on that basis, I--you know, our firm did prepare the return. [Emphasis added.] It is clear from his testimony that Mr. Knutzen did not have any independent knowledge of the origin of the funds used to acquire the muscle car collection. Rather, he relied solely on the representations of Mr. Garrett. His presumptions regarding the source of the funds for the muscle car collection do not rise to the level of fact. Mr. Knutzen testified that he never audited Mr. Garrett's corporations. He also admitted on cross- examination that Mr. Garrett could have expended $200,000 of the corporations' funds for personal expenses in 1987 or 1988 without Mr. Knutzen's knowledge. Furthermore, FGI, TTI, and BEL made substantial expenditures for the benefit of petitioners that were claimed as deductible business expenses by these corporations. These expenses total $755,827 for the 3 years in issue, most of which relate to Mr. Garrett's muscle car collection. Based on our review of the entire record in this case, including the lack of any documentation supporting petitioners' expenditures for the purchase and renovation of the muscle cars, the pattern of disallowed deductions taken during the years inPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011