- 14 - 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 hePage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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