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reported on the 1994 and 1995 tax returns. In addition,
respondent pointed out numerous inconsistencies in petitioners’
records at trial. Several times, Ms. Rhodes listed a mileage
amount that she claimed was to give a wedding estimate, but there
was no location listing where she drove. At trial, Ms. Rhodes
was unable to identify any of these missing locations, nor could
she remember the names of people she purportedly met for wedding
estimates. Other times, Ms. Rhodes listed travel to a particular
store to buy supplies but could furnish no receipts to support
the purchases. Several transactions, such as supplies trips,
were listed twice on her calendar. Finally, Ms. Rhodes often
grossly overestimated the miles she drove to a particular
location. For instance, she claimed she drove from Garrett to
Toledo to give a wedding estimate. The calendar listed mileage
of 542.4; however, the distance between Garrett and Toledo is 133
miles; therefore, the round trip distance would be 266 miles.
Ms. Rhodes offered no explanation for these inconsistencies.
Ms. Rhodes claims she and Mr. Rhodes never purchased new
tires, had any repair work done, or paid for oil changes, nor did
she have any documentation of her odometer readings for 1994 or
1995. Thus, petitioners failed to present any independent
evidence supporting the mileage claims. The Court finds that all
of Ms. Rhodes’s records relating to mileage reported in support
of Keepsake are false based on the absence of records and other
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