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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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