Estate of David J. Dickerson, Deceased, Dorothy Dickerson, Executor and Dorothy Dickerson, et al. - Page 14

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          and payable to Michoff, Jr.  Michoff, Jr., then endorsed the                
          check over to the Dickersons.  This money was given to the                  
          Dickersons by Michoff, Jr., either as a gift or as a loan and is            
          not therefore taxable to the Dickersons.                                    
               Respondent identified gambling as a source of the                      
          Dickersons' additional income.  Dorothy Dickerson loves to                  
          gamble.  Dorothy Dickerson could not identify what amounts she              
          won and lost at gambling.                                                   
               Respondent further contends that the Dickersons engaged in             
          transactions with Michoff, Jr., from whom they received moneys              
          and with whom they freely transferred property.  Respondent                 
          contends that Michoff, Jr., had sources of income which included            
          a lucrative activity of selling drugs.  Respondent has not made             
          any preliminary showing of why income from a drug selling                   
          activity of Michoff, Jr., should result in income to the                    
          Dickersons.  However, respondent has shown gambling to be a                 
          possible source of additional income which is sufficient to                 
          satisfy respondent's initial burden of connecting the Dickersons            
          to an income-producing activity.  Furthermore, even without this            
          showing, respondent has met her minimal evidentiary burden by               
          performing a bank deposits analysis.                                        
               With respect to all items except the $5,500 deposit,                   
          petitioners have failed to show that the source of the funds was            
          nontaxable.  Respondent's determination is sustained as to all              
          amounts above the $5,500.                                                   

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