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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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