Estate of David J. Dickerson, Deceased, Dorothy Dickerson, Executor and Dorothy Dickerson, et al. - Page 24

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          argues that the evidence shows that the Michoff, Srs., freely               
          transferred moneys and property between themselves and Michoff,             
          Jr., and that Michoff, Jr., was involved in the sale of drugs               
          during this period, which resulted in substantial income to                 
          himself and to his family, including the Michoff, Srs.                      
          Respondent contends that the Michoff, Srs., received money from             
          Michoff, Jr., from his drug business but offers no explanation of           
          why this would be taxable to the Michoff, Srs.  We conclude that            
          this is not a taxable source of income to the Michoff, Srs.                 
               Respondent did, however, analyze the bank deposits and                 
          expenditures of the Michoff, Srs., to determine the amount of               
          unreported income.  Petitioners have failed to prove that any of            
          the disputed amounts are from nontaxable sources.  Respondent is            
          sustained on this issue.                                                    
          Casualty Losses and Telephone Expenses                                      
               The Michoff, Srs., claimed miscellaneous itemized deductions           
          for alleged job required phone usage in the 1989 and 1990 tax               
          years in the amounts of $264 and $394, respectively.  The                   
          Michoff, Srs., admitted on brief that no evidence was provided to           
          establish the deductions claimed for the alleged job required               
          phone usage.  Petitioners failed to meet their burden of proof,             
          and therefore respondent's determination regarding the deductions           
          for phone usage is sustained.                                               
               The Michoff, Srs., claimed itemized casualty loss deductions           
          for the 1989 and 1990 tax years in the amounts of $3,965 and                

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