- 21 - Columbia’s ending inventory for 1995 consisted of whatever no-cost items remained from its 1995 opening inventory, plus the items purchased for $18,742 (including 14 junked vehicles) plus the $2,450 expended on supplies (as previously discussed). Thus, Columbia’s ending inventory had a cost of $21,192. Petitioners contend that the market value of Columbia’s 1995 ending inventory was only $1,500, which they argue was the scrap value of the 1995 ending inventory. Petitioners have failed to substantiate their claimed market value “by providing evidence of actual offerings, actual sales, or actual contract cancellations.” Thor Power Tool Co. v. Commissioner, 439 U.S. 522, 535 (1979). In any event, petitioners’ contention is contradicted by Samuel’s admissions in the Owner’s/Rebuilder’s Affidavits filed with the DMV in 1995, certifying that the NADA estimated fair market values of just four of the rebuilt automobiles in Columbia’s inventory totaled $32,100.10 Petitioners’ contention is further undermined by evidence showing that these four rebuilt automobiles, along with another vehicle 10 Although Columbia transferred title to the rebuilt vehicles to Monty for no consideration before the vehicles were sold to third parties, Samuel testified that the transfers to Monty were not gifts, stating: “The fact is that these vehicles were put in his [Monty’s] name in order to sell it [sic]. All of them were reported as income through our business.” Consequently, we ignore petitioners’ transfers of the rebuilt automobiles to Monty.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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