Benjamin and Sallie Campfield - Page 18

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          petitioner's behalf.  Leroy Campfield also purchased a planter,             
          but petitioner denies ownership of the planter.                             
               The combine, harrow, and planter were each purchased from              
          the same dealer.  The invoices associated with the purchase of              
          the combine and harrow show Campfield farm as the purchaser.  The           
          invoice associated with the planter shows Campfield farm as the             
          purchaser.  Leroy Campfield was acting on petitioner's behalf at            
          Campfield farm, and it seems highly unlikely that he would buy a            
          planter for something other than farm purposes, particularly when           
          the planter fits logically into the farm activities.  We find               
          that petitioner owned the planter.                                          
               Purchase of Casino Chips                                               
               Respondent determined that petitioner purchased casino chips           
          on May 19, 1985, in the amount of $13,100, and on November 29,              
          1986, in the amount of $10,700.  Respondent considered these                
          amounts nondeductible personal expenses.                                    
               Tropworld filed at least two CTR's that relate to                      
          petitioner.  The first CTR indicates that petitioner purchased              
          $13,100 of casino chips on May 19, 1985.  The second CTR                    
          indicates that petitioner purchased $10,700 of casino chips on              
          November 29, 1986.  The List Account maintained by Tropworld                
          shows that on May 19, 1985, petitioner purchased casino chips in            
          the amounts of $9,000, $2,000, $500, and $1,600, which                      
          corresponds with the $13,100 shown on the CTR for that date.  The           






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