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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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