Arlan L. Rower and Sandra M. Howard - Page 14

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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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