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With respect to the deposit of $6,222.89 on May 30, 1989,
petitioners' bank statement from Far West Federal does not show
that a transfer of $6,222.89 was made from their account at that
bank to their account at Washington Federal in or around May
1989. Assuming arguendo that the source of the $6,222.89 deposit
on May 30, 1989, into petitioners' account at Washington Federal
was a transfer from an account at Far West Federal, the record
does not contain any evidence as to the account at Far West
Federal from which that transfer may have been made or the
purpose of such transfer.
With respect to the deposit of $1,630.11 on May 2, 1990,
petitioners rely on the general and vague testimony of petitioner
that that deposit represented proceeds from the sale of a truck
that petitioners sold at a loss. The record contains no evidence
relating to the cost of that truck or its basis in petitioners'
hands at the time of its sale.
On the instant record, we find that petitioners have failed
32(...continued)
deposits at issue are not taxable. In this regard, assuming
arguendo that we were to find petitioners' schedules of deposits
and Ms. Harp's testimony regarding those schedules to be reli-
able, we found neither those schedules nor that testimony helpful
in determining whether those deposits are not taxable. Petition-
ers' schedules of deposits either do not identify the sources of
certain of the miscellaneous deposits at issue or identify the
sources of certain of those deposits without providing petition-
ers' explanation as to why they are not taxable. Ms. Harp's
testimony regarding petitioners' schedules of deposits, which was
general, vague, and conclusory, did not provide any additional
explanation on behalf of petitioners as to why the miscellaneous
deposits at issue for each of the years at issue are not taxable.
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