Herbert L. Whitehead and Jennifer L. Whitehead - Page 18




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               The specific Burien Nissan automobiles that each petitioner            
          used during the years at issue varied throughout those years.               
          Neither petitioners nor Burien Nissan maintained records showing            
          which Burien Nissan automobiles each petitioner used during those           
          years.  During the years at issue, Burien Nissan paid part of the           
          fuel and maintenance costs for those Burien Nissan automobiles,             
          and petitioners paid part of those costs.                                   
               Mr. Whitehead selected the specific Burien Nissan automo-              
          biles that Ms. Whitehead and he, respectively, used during the              
          years at issue.  The average value of the new Burien Nissan                 
          automobiles that Ms. Whitehead used during 1996 was $24,000.  The           
          average value of the new and used Burien Nissan automobiles that            
          Mr. Whitehead used during 1996 was $18,000.                                 
               Neither petitioners nor anyone else prepared or maintained             
          any document that purported to show either the amount or the                
          purpose of Ms. Whitehead’s use of certain Burien Nissan automo-             
          biles during the years at issue.                                            
          Mortgage Interest and Property Taxes                                        
               During the years at issue, petitioners owned and resided on            
          real property located at 2419 199th Avenue Court East, Sumner,              
          Washington (Sumner property).  During those years, Home Servicing           
          of America (Home Servicing) held a mortgage loan on that prop-              
          erty.  During the years at issue, petitioners paid Home Servicing           
          the following amounts for mortgage interest and property taxes              






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Last modified: May 25, 2011