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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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