Oliver E. Stubblefield - Page 18

                                   - NEXTRECORD  -                                    
          purchase with Metropolitan without petitioner's alleged                     
          intervention, assuming that such transaction was for her benefit.           
               Petitioner did not use his account with McDuff's Appliances            
          in 1991 other than to purchase a projection screen television               
          that cost approximately $2,000.  However, the record does not               
          indicate that the purchase was made for other than petitioner's             
          benefit.  Interestingly, Ms. Rawls never mentioned this item when           
          she testified.  We think that the purchase of a $2,000 projection           
          screen television would stick in one's mind, especially if one's            
          income were $16,645.                                                        
               Although it is true that petitioner carried over from 1990             
          an outstanding balance on certain of his accounts, namely, his              
          Citibank MasterCard ($631.22), his Discover card ($447.26), and             
          his account with Foley's ($589.49), the record does not disclose            
          what goods or services had been charged to give rise to such                
          balances.                                                                   
               It is also true that in September 1989 petitioner purchased            
          several pieces of furniture and related hardware from                       
          Metropolitan for a cash price of $1,157 and that he financed this           
          purchase.  On brief, petitioner argues that respondent's                    
          determination of unexplained bank deposits should be reduced by             
          $1,157 as a nontaxable reimbursement.  Petitioner would have us             
          ignore the terms of the retail installment contract that                    
          obligated him to make 18 payments of approximately $58.50 per               
          month commencing November 1989.  Therefore, if petitioner were as           




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