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sists of (1) lists and summaries, presumably prepared by or on
behalf of petitioner (petitioner's summaries), that purport to
show with respect to certain automobiles their respective pur-
chase prices, repair or other expenses, and, in certain instanc-
es, sales prices; (2) check stubs of petitioner that appear to
correspond to certain alleged purchase price and expense amounts
shown in petitioner's summaries; and (3) receipts for certain of
the expenses shown in those summaries that indicated that the
following customers were responsible for the expenses incurred:
Number of Receipts
Customer Name Listing Customer Name
Nathanael Roman 11
Shirley Ridgway 8
Matthew Roman 1
Aunt Shirley's Auto Sales 1
Robert's Auto Repair 6
We are unwilling to rely on petitioner's self-serving
summaries to establish that during 1990 and 1991 he was in the
business of purchasing, repairing, and reselling automobiles.
Although certain check stubs of petitioner and receipts for
repairs that are in evidence support petitioner's position that
during 1990 and 1991 he paid the repair and other expenses for
certain automobiles, we are not persuaded by the documentary (and
other) evidence introduced by petitioner on this issue that
during those years he owned the automobiles listed in peti-
tioner's summaries and that he attempted to, and/or did, sell any
of those automobiles for profit during those years.
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