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stand--as he was scared of committing perjury--and being exposed
as a blatant liar."
With respect to whether petitioner had the requisite profit
objective under section 183 for his automobile repair activity,
petitioners offered, inter alia, the following evidence: (1) The
testimony of Ms. Kahn, who is related to petitioner; (2) the
testimony of Mr. Goldberg, who has a family relationship with
petitioner; (3) a receipt book that reflected cash that petition-
ers received during 1993 (1993 receipt book); (4) computer-
generated lists of petitioners' alleged receipts, assets and
asset values, gasoline expenses, and supplies for 1992 (1992
computer lists) and their alleged assets and asset values for
1993 (1993 computer list) that were copied from a document
entitled "original business ledger"; and (5) a log that appears
to reflect miles traveled on certain trips in petitioner's
Ferrari during 1992 and in Ms. Howard's Thunderbird during 1993
that are alleged to be business trips (automobile log).
Mr. Goldberg and Ms. Kahn each testified that during 1993
petitioner charged them for repairs that he made to their respec-
tive automobiles. However, their testimony does not establish,
and there is no other evidence in the record to show, whether the
amount that petitioner charged them was enough to allow peti-
tioner to earn a profit from the automobile repair work that he
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