Oliver E. Stubblefield - Page 20

                                   - NEXTRECORD  -                                    
               We also fail to comprehend how petitioner could handle a               
          $385 monthly car payment on his reported income.  After all, 12             
          monthly payments of $385 equal $4,620, an amount in excess of               
          petitioner's reported gross income for 1991.  Even if, as                   
          alleged, petitioner's cousin helped service the loan by                     
          reimbursing petitioner $50 to $100 per month for her use of the             
          vehicle, petitioner's yearly car payment would have ranged from             
          $3,420 (i.e., 12 x ($385-$100)) to $4,020 (i.e., 12 x ($385-                
          $50)).  Any amount in this range would have represented a                   
          disproportionate percentage of petitioner's reported gross income           
          for 1991.                                                                   
               We also take note of the fact that the vast majority of the            
          deposits made to petitioner's bank accounts were made in cash and           
          that petitioner's barber business was a cash business.                      
          Significantly, none of the checks deposited to petitioner's                 
          accounts were drawn by either petitioner's sister or his cousin.            
          Although the record contains no details concerning the employment           
          or income, if any, of petitioner's sister, the record does show             
          that petitioner's cousin was employed by Methodist Hospital in              
          Houston and received wages of $16,645 in 1991.  Presumably                  
          petitioner's cousin was paid her wages by check.  We fail to                
          comprehend why, therefore, she would have "reimbursed" petitioner           
          in cash, particularly given the fact that petitioner maintained             
          bank accounts.                                                              






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