Herbert L. Whitehead and Jennifer L. Whitehead - Page 30




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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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