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disputes with respect to Ms. Whitehead’s use of certain Burien
Nissan automobiles during the years at issue are whether:
(1) Ms. Whitehead performed services for Burien Nissan during the
years at issue for which she was compensated by her personal use
of certain Burien Nissan automobiles during those years; (2) in
the performance of such services, Ms. Whitehead worked at least
120 hours during each year at issue; and (3) for 1996, petition-
ers correctly reported the value of Ms. Whitehead’s services in
their joint return for that year as self-employment income in the
amount of $6,600.37
36(...continued)
lished through their testimony at trial that, at least during
1996, Ms. Whitehead “used her vehicle for business purposes and
no adjustment was made for such use or for fuel purchased by
petitioner[s] from personal funds.” However, petitioners indi-
cate on brief that they will adhere to the “conservative ap-
proach” that they claim they took in their joint return for each
of the years at issue, in which they reported income from their
respective claimed personal uses of certain Burien Nissan automo-
biles during those years. That “conservative approach” was based
on the alleged business use of certain Burien Nissan automobiles
by Mr. Whitehead only, and not by Ms. Whitehead.
Assuming arguendo that petitioners had not adhered to the
“conservative approach” that they claim they took in their joint
return for each of the years at issue and that petitioners are
contending that any portion of Ms. Whitehead’s use of certain
Burien Nissan automobiles during the years at issue constituted a
business use of such automobiles, on the record before us, we
find that petitioners have failed to show that any portion of her
use of such automobiles during those years constituted a business
use of such automobiles.
37Petitioners allege as facts that, for each year at issue,
Ms. Whitehead performed services for Burien Nissan, she was
compensated for such services through her personal use of certain
(continued...)
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