- 17 - petitioner reported a $227,061 gain from this sale. The parties agree that petitioner miscalculated the gain from the disposition of the property, and the amount in the notice of deficiency is correct. Petitioner, however, now contends that Olympic was the true owner of this property, and the gain from the sale of the equipment should be reported by Olympic and not petitioner. Petitioner’s contention, however, is wholly unsupported in the record. At trial, Mr. Bone, petitioner’s 51-percent owner, in response to the question of who owned the equipment, replied that petitioner owned it. Petitioner also failed to present any evidence regarding the agreement between petitioner and Olympic with respect to the equipment under consideration. Consistent with respondent’s determination and petitioner’s reporting of the transaction is the fact that Olympic’s 1991 and 1992 tax returns included $125,816 and $146,847, respectively, in equipment lease deductions. Olympic’s reporting of lease payments supports our holding here that the arrangement between petitioner and Olympic was a lease. Accordingly, respondent’s determination regarding the gain on the sale of equipment is sustained. Overstatement of Inventory Findings of Fact Petitioner listed its 1991 ending inventory as $30,602. Petitioner listed its 1992 beginning inventory as $91,668. The difference is attributable to Olympic’s 1992 discontinuation ofPage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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