Estate of David J. Dickerson, Deceased, Dorothy Dickerson, Executor and Dorothy Dickerson, et al. - Page 13

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          purchase the cashier's check, nor did they otherwise prove that             
          the funds to purchase the check came from the El Dorado account.            
          Petitioners have failed to establish that the cashier's check was           
          purchased with funds from nontaxable sources.                               
               Dorothy Dickerson testified that some of the money that she            
          deposited into her El Dorado savings account was from checks from           
          Michoff, Jr., her grandson, and that the rest was from cash that            
          she had gathered “here and there.”  Petitioners further argue               
          that the deposits came from gambling winnings that were offset by           
          losses.  For both the 1989 and 1990 tax years, the Dickersons               
          reported substantial income from gambling as well as losses to              
          offset that income.  In performing the bank deposits analysis,              
          respondent's agent backed out any gambling income that was                  
          reported on the Dickersons' income tax returns.  The Dickersons             
          have failed to prove any additional gambling losses beyond those            
          already reported by them and allowed by respondent in the 1989              
          and 1990 tax years.                                                         
               Additionally, petitioners contend that the $9,200 which they           
          paid toward their Primeline credit account came from their cash             
          reserves as well as previous withdrawals from that account.                 
          Petitioners, however, offered no persuasive evidence to                     
          substantiate this claim.  Petitioners have failed to meet their             
          burden of proof regarding this amount.                                      
               A $5,500 deposit made into the El Dorado account on March              
          20, 1989, came from a cashier's check purchased by Dan Maggard              

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