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From what I've seen R32s don't tend to rot at the shock towers the way R33s, R34s and WC34s do because the newer cars have multiple layers of metal there for rot to work its way between, R32s don't. Same way S13s rot there because of that reinforcement plate that bridges the strut tower and apron.
Spare tire well surface rust usually indicates leaky taillights which could point to more problems (inner rear quarters, rear seat floor pan) or could be isolated.
Would be easy to sus out with an in-person inspection which is about the only benefit of buying from a place like JC.
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