Samuel T. Seawright and Carol A. Seawright - Page 21




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               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.                                                       





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