- 30 - 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.Page: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 Next
Last modified: May 25, 2011