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assertions. Accordingly, petitioner is entitled to an additional
$20,515 of basis in WIS for 1990, corresponding to the sum of the
sale prices of the two Toyota pickups, the Toyota Cressida, and
the Ford Bronco as well as one-half the sale price of the Ford
Aerostar.
There is no persuasive evidence of any further investments
in WIS by petitioner before or during the years at issue.
Although petitioners did introduce personal credit card
statements reflecting cash advances in the total amount of $7,300
during 1990, there is no evidence in the record that any of these
advances were used on behalf of WIS rather than for petitioner’s
personal consumption. For this reason respondent properly denied
petitioner basis credit for any portion of this amount.
Petitioners also introduced deposit slips evidencing three
deposits into WIS’s account at Palmetto Federal during 1990 in
the total amount of $2,250. The deposit slips identify the
amounts as loans. However, petitioners failed to prove that
petitioner was the source of the loans.
Petitioners urge the Court, in the absence of direct
evidence, to infer that petitioner’s investment in WIS was
sufficient to deduct the full amount of the losses claimed on
their individual returns. First, they argue that, although
petitioner possessed documentation necessary to substantiate the
amount of his basis in WIS, the revenue agents neglected to
request it. Three months before trial, in August 1995, “since
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