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In 1992, Columbia “crushed out” all its inventory of junked
vehicles and other items, selling it as scrap metal. In 1993 and
1994, Samuel continued to haul various items to petitioners’
scrap yard, including junked or abandoned vehicles. Petitioners
did not pay for any of the items Samuel hauled away during these
years. The only gross receipts generated from Columbia’s
business during 1993 and 1994 were attributable to some
automobile body work and other labor that Samuel performed.
In 1995, Columbia recommenced rebuilding junked vehicles.
Between April and December 1995, petitioners spent a total of
$18,742 to purchase 14 junked vehicles (at a total cost of
$17,285) and various automotive parts (at a total cost of
$1,457). Petitioners bought a number of these junked vehicles at
auctions conducted by Sadisco of Columbia (Sadisco), a company
which operated as a middleman between insurance companies in
possession of wrecked automobiles and dealers who buy them.
During 1995, Columbia rebuilt or was in the process of
rebuilding at least six damaged vehicles, five of which were sold
to third parties in 1996 for an aggregate sales price of
$23,400.2 As required by State law, along with the application
of certificate for title/registration for each of these six
vehicles, there was filed with the South Carolina Department of
2 None of the rebuilt vehicles were sold in 1995. During
1995, petitioners sold none of its inventory to scrap dealers.
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