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In this case, therefore, a total of $4,617.78 in 1988,
and $23,940.10 in 1989, of H&B's funds was used to pay
expenses related to the Lincoln Mark VII. Respondent
determined that these amounts constitute income to
petitioners because the Lincoln, at all relevant times, was
used by petitioner as his personal vehicle. Petitioners
bear the burden of proving that respondent's determination
in this regard is erroneous. See Rule 142(a). We find
that petitioners have failed to satisfy this burden.
Petitioners argue that these payments do not con-
stitute income to them because the Lincoln was a "company
car". Presumably, petitioners argue that the automobile
was used for H&B's business purposes, or that the payments
constitute nontaxable fringe benefits. We find this
argument unpersuasive. First, the title to the automobile
lists Pet-Don, not H&B, as owner. Second, petitioners have
not shown that petitioner used the automobile for any
purpose benefiting the title holder of the car, Pet-Don,
or the payor of the subject payments, H&B. Petitioner did
not maintain any record of the purposes for which the
automobile was used, nor did he testify that it was used
primarily to further H&B's business purposes. To the
contrary, petitioner testified that he used a second
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