Estate of David J. Dickerson, Deceased, Dorothy Dickerson, Executor and Dorothy Dickerson, et al. - Page 12

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          amounts of $55,097 and $2,800 for the tax years 1989 and 1990,              
               The Dickersons made specific payments on their Primeline               
          credit account in the total amount of $9,200, which is in issue             
          in the 1989 tax year.  These were not, however, the total                   
          payments made by the Dickersons on their Primeline credit account           
          in the 1989 tax year.                                                       
               The Dickersons made deposits into their El Dorado savings              
          account in the amounts of $37,100 and $2,800 in the 1989 and 1990           
          tax years, respectively.  These were not the total deposits made            
          into this account in the 1989 and 1990 tax years.                           
               Respondent also identified a cash expenditure which she                
          added to the unreported income of the Dickersons for the 1989 tax           
          year.  This expenditure was the purchase of a cashier's check in            
          the amount of $8,797 for purposes of purchasing the Green Ridge             
          Drive residence.                                                            
               Petitioners argue that the $8,797 cashier's check was                  
          purchased with loans from Dan Maggard.  However, the check from             
          Dan Maggard was deposited into the El Dorado account.                       
          Petitioners failed to show a canceled check that was used to                

               4  Petitioners objected to respondent's proposed finding of            
          fact which reads as follows:  "Respondent's revenue agent                   
          conducted a bank deposits analysis of the Dickerson's income for            
          1989 and 1990."  On brief, however, petitioners do not dispute              
          that respondent's revenue agent conducted a bank deposits                   
          analysis; rather they argue that it was conducted improperly.               
          This is typical of the argumentative and contradictory statements           
          that appear throughout petitioners' briefs.                                 

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