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1991 Whitehead/Stanford stock purchase agreement. We find on the
record before us that Mr. Stanford owned no Burien Nissan stock
after September 13, 1991, and that Burien Nissan could not have
redeemed any stock from Mr. Stanford in 1995. We shall not rely
on the AJE 15 entries to support petitioners’ position that
Burien Nissan redeemed Mr. Stanford’s Burien Nissan stock in
1995.
With respect to the issue of Mr. Whitehead’s use of certain
Burien Nissan automobiles during the years at issue, petitioners
rely on, inter alia, a document entitled “AUTOMOBILE MILEAGE AND
EXPENSE LOG” (purported mileage log). Petitioners contend that
Mr. Whitehead maintained that purported mileage log during
January, February, and March 1996 in order to determine what
portion of his use of certain Burien Nissan automobiles during
the years at issue constituted a business use of those automo-
biles. Based upon our examination of the purported mileage log,
we found it to be questionable. That purported log contained
different handwriting and certain numerical entries which ap-
peared to have been altered.24 We shall not rely on the pur-
ported mileage log.
Burien Nissan’s Payments to Mr. Stanford
Respondent determined to increase petitioners’ taxable
24We also found certain numerical entries contained in the
purported mileage log to be illegible.
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