Maintenance, Painting & Construction, Inc. - Page 9

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          were or were not left there.  The record contains no                        
          contemporaneous documentation as to the equipment which was                 
          placed on the lot, or the equipment on the lot that was                     
          eventually shipped to Tennessee.  Petitioner relies predominantly           
          on the workpapers prepared by Tacker to establish the equipment             
          which it claims was abandoned, as well as on the conclusory                 
          testimony of Tacker and Laxton to the effect that those                     
          workpapers are accurate.  The probative value of these workpapers           
          is minimal, as is the referenced testimony.  In addition to the             
          fact that the workpapers were prepared during this proceeding,              
          Tacker testified that his knowledge as to the specific assets               
          which he showed thereon as abandoned was derived entirely from              
          Laxton.  Laxton, in turn, offered no clear explanation as to why            
          he believed these workpapers were accurate, although he was                 
          specifically asked to do so upon cross-examination.                         
               We also question the accuracy of Exhibit 8-P when we examine           
          the specific assets shown thereon which petitioner claims were              
          useless after May 31, 1995, and abandoned in 1997.  For example,            
          as to those assets, the exhibit lists that petitioner purchased a           
          1987 truck during its 1995 taxable year at a cost of $22,588.               
          This truck cost substantially more than the numerous other trucks           
          used by petitioner on the contract, and petitioner generally used           
          each of those other trucks for more than 1 year.  We are hard               
          pressed on the record at hand to conclude that the 1987 truck was           






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