Thomas A. Johnson - Page 8

               We find that the deposits to the Ticketline account were               
          income to petitioner and were not loan repayments from Finnimore.           
          See Dean v. Commissioner, 57 T.C. 32, 45 (1971).                            
               Petitioner argues in the alternative that, if the $167,949             
          is income from the sale of tickets, he is entitled to reduce the            
          income by the cost of the tickets sold.  Petitioner did not keep            
          adequate records of the moneys he advanced to Finnimore.                    
          Petitioner, therefore, looks to numerous canceled checks and cash           
          withdrawals, which he maintains were advances to Finnimore.                 
          Petitioner argues that checks payable to cash, in even amounts of           
          $1,000 or more, were moneys he advanced to Finnimore for the                
          purchase of tickets.  Petitioner concedes that some small portion           
          of those checks was retained by him for personal purposes but               
          argues that the balance went to Finnimore for the purchase of               
          tickets.  The amounts set forth in the appendix reflect the                 
          amounts advanced to Finnimore after allowing for petitioner's               
          concessions.  We find that petitioner advanced to Finnimore for             
          the purchase of tickets $69,700 from the Ticketline account,                
          $13,300 from the Todge Trust account, $43,250 from the equity               
          credit line, and $5,000 from the ULC account.  These payments are           
          detailed in the appendix.                                                   
               Petitioner paid $6,254 for tickets using his credit card,              
          and this amount is allowable as cost of goods sold.                         
               Petitioner contends that he purchased tickets directly from            
          a ticket agent with check No. 1076 in the amount of $2,500 and              

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